{"id":9181,"date":"2019-10-29T13:19:38","date_gmt":"2019-10-29T18:19:38","guid":{"rendered":"http:\/\/blogs.edf.org\/health\/?p=9181"},"modified":"2024-02-12T11:02:22","modified_gmt":"2024-02-12T16:02:22","slug":"epas-just-released-methylene-chloride-draft-risk-evaluation-some-important-context","status":"publish","type":"post","link":"https:\/\/blogs.edf.org\/health\/2019\/10\/29\/epas-just-released-methylene-chloride-draft-risk-evaluation-some-important-context\/","title":{"rendered":"EPA\u2019s just-released methylene chloride draft risk evaluation: Some important context"},"content":{"rendered":"<p><em>Richard Denison, Ph.D.,\u00a0<\/em>is a Lead Senior Scientist.<\/p>\n<p>After <a href=\"https:\/\/blogs.edf.org\/health\/2019\/10\/02\/next-tsca-chemical-peer-reviews-and-draft-risk-evaluations-to-be-delayed-youll-never-guess-why\/\">more than a month\u2019s delay<\/a>, EPA <a href=\"https:\/\/www.epa.gov\/assessing-and-managing-chemicals-under-tsca\/draft-risk-evaluation-methylene-chloride\">today released<\/a> its draft risk evaluation for methylene chloride.\u00a0 Running to 725 pages (not counting more than a dozen supplemental files), it will take some time to digest.\u00a0 But here are some initial observations that provide context for those of you who will be looking closer.<\/p>\n<p>First, methylene chloride is a very nasty chemical.\u00a0 It has killed a lot of people.\u00a0 It causes cancer.\u00a0 Short- and long-term exposure to it is tied to liver effects, immune system effects, nervous system effects, and reproductive\/developmental effects.<\/p>\n<p>So it shouldn\u2019t be surprising that EPA\u2019s draft \u2013 even coming from an administration not known to be overly worried about the risks of chemicals \u2013 has found that most industrial, commercial and consumer uses of methylene chloride present unreasonable risks.<\/p>\n<p>For example, EPA found that workers using methylene chloride-based paint strippers face high risks.\u00a0 Of course, we knew that already:\u00a0 EPA identified those risks <a href=\"https:\/\/www.epa.gov\/assessing-and-managing-chemicals-under-tsca\/risk-evaluation-methylene-chloride-0#pre-lautenberg\">more than five years ago<\/a>, and proposed to ban those uses.\u00a0 This EPA decided it had to do it all over again \u2013 which means that thousands of workers have continued to be unnecessarily exposed to this deadly chemical.\u00a0 And it will be even more years before we get back to where we were before EPA took its mulligan.<\/p>\n<p>So the good news is that EPA seems to be acknowledging that methylene chloride presents high enough risks to warrant regulation under the Toxic Substances Control Act (TSCA).<\/p>\n<p>The bad news is that EPA is dramatically underestimating the magnitude of methylene chloride\u2019s risks \u2013 by pulling the same tricks it has for other chemicals among the first 10 it is evaluating under TSCA:<\/p>\n<ul>\n<li>EPA once again <strong><em>ignores all exposures and risks to the general population<\/em><\/strong> by falsely assuming those exposures and risks are eliminated by actions it has taken or could take under other laws. That means ignoring over 4 million pounds of methylene chloride annually released to air, water and land.\u00a0 See <a href=\"https:\/\/blogs.edf.org\/health\/wp-content\/blogs.dir\/11\/files\/2019\/10\/Methylene-Chloride_Summary-FINAL.pdf\">this backgrounder<\/a> for the details and why this EPA assumption about methylene chloride is deeply flawed.<\/li>\n<li>EPA once again <a href=\"https:\/\/blogs.edf.org\/health\/2019\/02\/21\/the-trump-epa-is-throwing-workers-facing-risks-from-new-tsca-chemicals-under-the-bus\/\">grossly understates risks to workers<\/a>:\n<ul>\n<li>EPA <strong><em>assumes that workers will always wear fully effective personal protective equipment<\/em><\/strong> (respirators and gloves) to make many of the risks it identifies go away \u2013 and to grossly understate the magnitude of the unreasonable risks it does find.<\/li>\n<li>EPA once again finds a cancer risk to workers unreasonable <strong><em>only if it exceeds a level of 1 in 10,000<\/em><\/strong> \u2013 which is 100 times higher a risk than warrants regulation under TSCA to protect workers and other vulnerable subpopulations.<\/li>\n<li>For occupational non-users (ONUs), EPA has once again <strong><em>failed to identify unreasonable risks for the most highly exposed, and hence most vulnerable, workers<\/em><\/strong> unless it finds that the majority of workers also face unreasonable risks.<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n<p>These are just a few initial observations based on our reading of EPA\u2019s opus so far.<\/p>\n<p>So while it\u2019s somewhat encouraging that this new draft risk evaluation has found many more risks than previous drafts, we can already tell the draft falls far short of adequately describing the risks presented by methylene chloride.<\/p>\n<p>Stay tuned.<\/p>\n","protected":false},"excerpt":{"rendered":"<p>Richard Denison, Ph.D.,\u00a0is a Lead Senior Scientist. After more than a month\u2019s delay, EPA today released its draft risk evaluation for methylene chloride.\u00a0 Running to 725 pages (not counting more than a dozen supplemental files), it will take some time to digest.\u00a0 But here are some initial observations that provide context for those of you &#8230;<\/p>\n","protected":false},"author":100,"featured_media":8494,"comment_status":"open","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"footnotes":""},"categories":[68,44,5009,39263,56096,114108,77],"tags":[68,91777,107209],"coauthors":[],"class_list":["post-9181","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-epa","category-policy","category-health-science","category-public-health","category-omboira","category-tsca","category-worker-safety","tag-epa","tag-methylene-chloride","tag-paint-strippers"],"acf":[],"aioseo_notices":[],"_links":{"self":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/9181","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=9181"}],"version-history":[{"count":1,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/9181\/revisions"}],"predecessor-version":[{"id":12892,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/posts\/9181\/revisions\/12892"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/media\/8494"}],"wp:attachment":[{"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/media?parent=9181"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/categories?post=9181"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/tags?post=9181"},{"taxonomy":"author","embeddable":true,"href":"https:\/\/blogs.edf.org\/health\/wp-json\/wp\/v2\/coauthors?post=9181"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}