{"id":9100,"date":"2019-09-16T15:05:02","date_gmt":"2019-09-16T20:05:02","guid":{"rendered":"http:\/\/blogs.edf.org\/health\/?p=9100"},"modified":"2024-02-12T11:02:21","modified_gmt":"2024-02-12T16:02:21","slug":"epas-latest-move-to-deflect-criticism-of-its-tsca-risk-evaluations-muzzle-its-science-advisors","status":"publish","type":"post","link":"https:\/\/blogs.edf.org\/health\/2019\/09\/16\/epas-latest-move-to-deflect-criticism-of-its-tsca-risk-evaluations-muzzle-its-science-advisors\/","title":{"rendered":"EPA\u2019s latest move to deflect criticism of its TSCA risk evaluations: Muzzle its science advisors"},"content":{"rendered":"<p><em>Richard Denison, Ph.D.,\u00a0<\/em>is a Lead Senior Scientist.<\/p>\n<p>Readers of this blog know that Environmental Defense Fund (EDF) has voiced strong opposition to a number of decisions made by the Environmental Protection Agency (EPA) that aim to limit the risks it finds when evaluating the safety of chemicals under the Toxic Substances Control Act (TSCA).<\/p>\n<p>These decisions include:<\/p>\n<ul>\n<li><a href=\"https:\/\/blogs.edf.org\/health\/2018\/07\/05\/how-pruitts-epa-finds-a-dangerous-chemical-is-safe-ignore-most-exposures-to-it\/\">excluding from its analysis<\/a> known human and environmental exposures to a chemical, based on unwarranted assumptions that those exposures are adequately managed by other statutes;<\/li>\n<li><a href=\"https:\/\/blogs.edf.org\/health\/2019\/07\/22\/trump-epa-grossly-understates-the-risks-of-14-dioxane-to-workers-and-the-environment-while-ignoring-all-exposures-to-consumers-and-the-general-public\/\">claiming without support that workers are protected<\/a> by assuming universal and universally effective use of personal protective equipment throughout chemical supply chains and the adequacy of OSHA regulations that either don\u2019t apply or are decades out of date;<\/li>\n<li><a href=\"https:\/\/blogs.edf.org\/health\/2019\/07\/22\/trump-epa-grossly-understates-the-risks-of-14-dioxane-to-workers-and-the-environment-while-ignoring-all-exposures-to-consumers-and-the-general-public\/\">arbitrarily loosening EPA\u2019s longstanding risk standards<\/a> governing when cancer incidences are deemed unacceptably high; and<\/li>\n<li>choosing not to exercise its <a href=\"https:\/\/blogs.edf.org\/health\/2018\/12\/19\/the-trump-epas-first-risk-evaluation-under-the-new-tsca-is-a-house-of-cards\/\">enhanced authorities under TSCA<\/a> to require submission of robust information on chemicals\u2019 hazard and exposures, resorting instead to questionable assumptions and relying on voluntarily submitted industry data that are unrepresentative or of poor or indeterminate quality.<\/li>\n<\/ul>\n<p>Through these decisions, EPA increases the likelihood that it will either not find unreasonable risk and thereby avoid regulating the chemical, or if that can\u2019t be accomplished, find risks that are low enough that it can impose few restrictions, thereby burdening industry as little as possible.<\/p>\n<p>In response to each of these decisions, EPA has received dozens of highly critical comments on its draft risk evaluations from state and local governments, labor and health groups, environmental NGOs and members of the scientific community.\u00a0 And in the first several peer reviews conducted by its Scientific Advisory Committee on Chemicals (SACC), many of the scientists voiced quite similar concerns during the committee\u2019s public meetings (as of yet, final peer review reports have not been issued).<\/p>\n<p>Rather than address the problems, EPA has adopted a new tactic to stifle the criticism, one that is quite chilling (literally and figuratively):\u00a0 It is telling the SACC that these issues are off-limits to the peer reviewers because they represent policy decisions that are beyond the charge given to the SACC.\u00a0 This is beyond the pale, for several reasons.\u00a0 <!--more--><\/p>\n<p>First, such issues fall squarely within the SACC\u2019s charge.\u00a0 EPA\u2019s own \u201c<a href=\"https:\/\/www.regulations.gov\/document?D=EPA-HQ-OPPT-2019-0235-0003\">charge questions<\/a>\u201d provided to the SACC to guide its most recent peer review of 1-bromopropane (1-BP) specifically (and appropriately) call on the SACC to comment on the \u201cassumptions, uncertainties and data limitations in the methodology used to assess risks from 1-BP.\u201d<\/p>\n<p>Second, it is absolutely the SACC\u2019s role and responsibility to comment on the <em>scientific<\/em> consequences of EPA\u2019s decisions that directly affect its characterization of exposure, hazard, and risk.\u00a0 Such scientific input is especially vital here, as most of EPA\u2019s decisions clearly lead to underestimations of chemicals\u2019 risks \u2013 to the environment, the general population, workers, and vulnerable subpopulations.<\/p>\n<p>Third, with respect to the adequacy of the information EPA relies on, the agency has recently made an additional claim to the SACC: \u00a0that EPA has no choice but to use the data it has readily at hand, however limited they are.\u00a0\u00a0 In fact, EPA has had \u2013 and has made \u2013 a choice every single day during the entire 3 years its risk evaluations have been underway.\u00a0 When Congress expanded EPA\u2019s mandate to conduct comprehensive assessments of chemicals\u2019 safety, it understood EPA would need to obtain much more information on those chemicals than is currently available.\u00a0 That is why the 2016 amendments to TSCA significantly strengthened EPA\u2019s authority to require the reporting and development of chemical information.\u00a0 \u00a0And all along the way, EDF and many other commenters have repeatedly identified the data gaps and urged the agency to use those authorities to fill them, to no avail.<\/p>\n<p>EPA\u2019s choice under this administration has been stark:\u00a0 It has chosen not to use that authority even a single time.\u00a0 As a result, EPA lacks the information needed to conduct scientifically sound risk evaluations, which has implications for EPA\u2019s future as well as current chemical safety reviews.\u00a0 The SACC can and must clearly identify the resultant deficiencies and uncertainties in EPA\u2019s chemical risk evaluations.<\/p>\n<p>Sadly, EPA\u2019s shift in tactics is in keeping with this administration\u2019s general attitude toward science.\u00a0 It is but the latest in a series of moves to limit the scientific information and scientific advice that EPA can obtain and use to make decisions.<\/p>\n<p>&nbsp;<\/p>\n","protected":false},"excerpt":{"rendered":"<p>Richard Denison, Ph.D.,\u00a0is a Lead Senior Scientist. Readers of this blog know that Environmental Defense Fund (EDF) has voiced strong opposition to a number of decisions made by the Environmental Protection Agency (EPA) that aim to limit the risks it finds when evaluating the safety of chemicals under the Toxic Substances Control Act (TSCA). These &#8230;<\/p>\n","protected":false},"author":100,"featured_media":9102,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[44,5009,56093,56096,114108],"tags":[113939,107195,68],"coauthors":[],"class_list":["post-9100","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-policy","category-health-science","category-industry-influence","category-omboira","category-tsca","tag-1-bromopropane","tag-dioxane","tag-epa"],"acf":[],"aioseo_notices":[],"_links":{"self":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/9100","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=9100"}],"version-history":[{"count":1,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/9100\/revisions"}],"predecessor-version":[{"id":12886,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/9100\/revisions\/12886"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/media\/9102"}],"wp:attachment":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/media?parent=9100"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/categories?post=9100"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/tags?post=9100"},{"taxonomy":"author","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/coauthors?post=9100"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}