EPA plans for calculating chemical risks just don’t add up

The United States Environmental Protection Agency (EPA) is making major changes in how it deals with hazardous chemicals, and the first 10 chemicals EPA is considering have a whopping combined production volume of over 1 billion pounds per year. That’s about 3 pounds of chemicals per person in the U.S., and we know that Americans are widely exposed to these chemicals — some taint our drinking water, others contaminate our homes, or waft from our dry-cleaned clothes.

As we wrote earlier this year, Congress recently overhauled the federal law, the Toxic Substances Control Act (TSCA), which is supposed to address toxic chemicals in everyday products like furniture, toys, building materials and cleaning products. One of the EPA’s first actions under the new TSCA is to evaluate risks to human health  (a process known as “risk evaluation”) for the 10 chemicals shown in the table below. These first 10 assessments are critical  because these chemicals are widespread in our homes and workplaces, and because these assessments will set the precedent for how EPA evaluates chemical risks for decades to come.

Table of the first 10 chemicals EPA is evaluating under the new TSCA with recent news stories where available.

Chemical Recent news stories
Asbestos Upended by America’s ‘third wave’ of asbestos disease (Center for Public Integrity)
1-bromopropane (1-BP, n-BP, n-propyl bromide) As OSHA Emphasizes Safety, Long-Term Health Risks Fester (New York Times)
Carbon tetrachloride (tetrachloromethane) Even though I’m an environmental reporter, the air quality in my home was eye-opening (Courier-Journal)
1,4-dioxane Cancer-Causing Pollutants Found In Westbury Water District Drinking Water, Study Shows (Hicksville Patch)
Hexabromocyclododecane (HBCD) Recycling plastics contaminate children’s toys with toxic chemicals (The Guardian)
Methylene chloride (MC, MEC, DCM, dichloromethane) Mother Questions Use of Chemical After Son’s Death (WebMD)
N-methylpyrrolidone (NMP)
Perchloroethylene (PERC, tetrachloroethylene) Vapor intrusion scare delays start for St. Paul school (Minneapolis Star Tribune)
Pigment violet 29
Trichloroethylene (TCE) Are Hazardous Vapors Seeping Into Your Home? (Ensia)

As these stories show, the stakes are high for communities in the U.S.; that’s why we’re concerned that EPA’s plans for analyzing these 10 chemicals’ risks (which EPA laid out in its “chemical scoping documents”) are missing key pieces. Without these pieces, EPA will not have the information it needs to keep families from being exposed to harmful chemicals.

For example, take the story of Kris Penny, who was exposed to asbestos at his job installing cables inside asbestos cement pipes. He contracted mesothelioma, a type of cancer caused by asbestos, and tragically passed away at age 40 in 2016. Such a scientifically clear and documented risk should be part of EPA’s evaluation of asbestos but as shown below in the snapshot from the scoping document, EPA specifically excludes considering exposures from asbestos cement pipes, amongst many other known uses of asbestos, from its risk evaluation plan.

Source: US EPA, 2017. Scope of the Risk Evaluation for Asbestos. Pg. 24

By doing this, the EPA is basically subtracting workers like Kris Penny from its risk equation — a choice that is scientifically unjustified and fails to reflect the true risks of asbestos, particularly for those exposed at work. This problem is one of many in the EPA’s plan that will lead to underestimating risks — and unfortunately, the problems are not confined to asbestos. This pattern of excluding chemical uses and exposures that contribute to risk is also apparent in the plans for the other 9 chemicals under review.

In scientific and technical comments submitted to the EPA today, UCSF PRHE along with 24 other scientists and health professionals outlined several major concerns with EPA’s plans for evaluating chemical risks, including significant chemical exposures that are missing for workers, consumers and the general population. But how, and how much of, a chemical gets into people’s bodies – the chemical exposure – is just one part of the information that goes into EPA’s risk calculations. Our future blogs will focus on other important ways that EPA can make sure they use the best science on behalf of the American public.

EPA’s methods of accounting for chemical risks are too important to get wrong right out of the gate. The consequences of EPA’s decisions – for better or worse – will be borne by people like Kris Penny, and millions of other workers, families, and children for decades to come.

Colorful chemicals