Overwhelming scientific evidence demonstrates that exposure to chemicals and pollutants in our environment affects our health, increases risk of disease, and jeopardizes children’s development. Public policies determine what and how much we are exposed to and thus, how much our health is at risk.
To protect public health, policies must be created using the best science and scientific methods. Unfortunately, that has not been the case in recent years. Even before the current administration, our approach to chemical policy allowed and continues to allow chemicals to stay on the market and affect our health long after scientists discover a problem.
While changes to EPA policies and laws, such as the Toxic Substances Control Act (TSCA) in 2016, attempted to address these inadequacies, the current administration’s implementation of TSCA illustrates how the changes fall short.
So how can we improve chemical policy and procedures to protect health?
PRHE worked with scientists and policy experts around the country to develop recommendations to improve hazard and risk assessment processes and policy making on harmful chemicals and pollutants at EPA:
Chemical Policy
Science has advanced on how industrial chemicals and environmental pollutants can adversely influence people’s health. However, despite some methodological improvement, the framework for evaluating the evidence in hazard and risk assessment has stayed largely the same since the 1970s, even though multiple authoritative review bodies have called for improved approaches. For example, EPA continues to use an approach that assumes there is no risk below a level assumed to be “safe” for the general population, including sensitive groups, such as infants, children, pregnant women, and marginalized communities.
PRHE recommends five actions to advance the science in hazard and risk assessment that include calling on EPA to assume that all health effects have some probability of occurring and to quantify risks accordingly, and that EPA should correct its definition of potentially exposed and susceptible populations to include everyone as the updated TSCA outlines.
Systematic Review
Systematic review methods are recommended by the National Academies of Sciences, Engineering and Medicine (NASEM) to better evaluate potential harms of environmental chemicals and inform decision-making; systematic review methods set the “rules” of the game for more transparent and consistent approaches to interpreting scientific evidence. Despite a requirement from TSCA to use the “best available science,” EPA is using a method that does not comply with current, established, best-available empirical methods for systematic review which has resulted in underestimating risks of environmental chemicals and pollutants.
PRHE recommends that EPA implement a science-based systematic review method that aligns with NASEM’s definition i.e., the National Toxicology Program’s OHAT method and UCSF’s Navigation Guide, and immediately employ such a method for the ongoing TSCA risk evaluations and use the same systematic review method for hazard identification, characterization and risk assessment across the Agency.
Conflicts of Interest
“The biggest threat to [scientific] integrity [is] financial conflicts of interest,” JAMA’s deputy editor observed in 2010. Actions by the tobacco and pharmaceutical industries over decades demonstrate that when industry sponsors research, the results are more favorable to the sponsoring industry. Similar patterns are seen in research funded by the chemical industry.
EPA does not account for how it considers funding sources when reviewing scientific evidence despite a recommendation from NASEM to do so, nor has EPA addressed conflicts of interest (COI) among those the Agency appoints to scientific advisory boards.
PRHE recommends financial COI from industry funding should be considered a risk of bias in research and eliminated to the extent possible among individuals serving on EPA advisory boards.
Environmental Justice
Communities of color and low-income communities are disproportionately exposed to harmful chemicals, pesticides, and accidental industrial releases, and the way our government implements environmental laws does not ensure equal, socially just safeguards for environmental health.
PRHE recommends that science guide chemical policy to promote healthy outcomes for diverse communities and to ensure they have the same access to healthy environments. Additional resources need to be allocated to monitor and reduce environmental pollution and risks in overburdened communities, and build capacity for risk evaluations that comport with National Academies of Sciences’ recommendations. Finally, EPA needs to increase community engagement and accountability to ensure that EPA actions demonstrably reduce inequitable pollution exposures.
Data Infrastructure
We cannot manage what we do not measure. Therefore, EPA must invest in data infrastructure systems to better identify potential harms, risks, and effectiveness of interventions as well as prioritize areas of need for more equitable environmental health decisions. Investments to implement, house, and maintain the most up-to-date data include quantification of environmental contaminants both released and present in air, water, food, and consumer products, as well as data on environmental health-related diseases.
PRHE recommends that EPA invest in systems to support collecting, organizing, and making accessible environmental and health data that allows the agency and the public to understand, monitor and act on environmental factors that influence health, resulting in more equitable public health safeguards.
Research Funding
EPA and its workforce cannot keep pace with current scientific advances if the agency does not invest in research and workforce training to ensure it has the best science for decision-making.
PRHE recommends that EPA invest in next generation methods for understanding and characterizing environmental stressors, basic laboratory science to rapidly identify which and how chemicals and pollutants harm health, and Children’s Environmental Health and Disease Prevention Research Centers.
You can read the complete set of recommendations here.
PRHE has been at the forefront of defending science and promoting policies that incorporate science and protect the public’s health from harmful chemicals. Our public comments have shined a light on EPA practices that fail to protect public health and vulnerable populations such as children, and our recommendations have been validated by EPA’s own scientific peer-review panel on best practices for assessing hazard and risk. We urge policy-makers to adopt these recommendations to improve chemical policy making and the public’s health.
