In high school, Swati Rayasam thought she would study architecture or Russian literature. Then a friend almost lost his leg to an antibiotic resistant staph infection and she switched gears into science. Today she monitors EPA’s implementation of the updated Toxic Substances Control Act (TSCA) – the law that governs chemicals in commerce – for the Program on Reproductive Health and the Environment (PRHE). Rashmi Joglekar was earning her PhD at Duke University when she worked on a project to require testing for lead in drinking water at childcare centers. Her success led to her role as a scientist working in the Toxic Exposure & Health Program at Earthjustice. One of Max Aung’s first research experiences was analyzing ocean sediment from around the world to help improve models of future climate prediction. Now he investigates the relationship between prenatal exposure to harmful chemicals and adverse reproductive health outcomes at PRHE.
These three emerging leaders will present at American Public Health Association’s annual meeting on October 24, 2021 to discuss how EPA’s implementation of TSCA needs to be improved to better protect public health. We sat down with them to learn more about what they’re working on, and how and why they became environmental health scientists.
Q. Why did you want to become scientists?
Rashmi: What drew me to science was my love of biology. After taking an environmental policy class in college and learning about Superfund sites and environmental disasters like the Love Canal, I became passionate about understanding the impact of environmental contaminants on biological systems. This passion led me to obtain a doctorate in the field of toxicology.
Max: One of my first experiences in undergrad was in a paleo-oceanography laboratory where researchers went on expeditions to extract sediment samples from ocean systems across the world. We would analyze samples and reconstruct historic climate trends from the past thousands of years, including sea surface temperatures and water nutrient profiles to better inform models of future climate prediction. That was my exposure to environmental science with a dash of organic chemistry because we used complex crazy instruments to do these measurements. When I combined the environmental work with my main course work of immunology and microbiology, I started to think about the connection between the environment and human health and disease.
Swati: I never wanted to be a scientist. But then my best friend in high school contracted an antibiotic resistant staph infection. I had never heard of antibiotic resistance before and became interested in this battle between bacteria and us (humans) and seeing who could evolve faster. That led me to studying antibiotic resistant gonorrhea (great fodder for dating). Then I took an HIV/AIDS and policy course and worked with a clinician to look at testing discrepancies between rural and urban physicians, which got me interested in science and health policy interface. Working at Duke on an HIV and tuberculosis co-vaccine got me into global health, and eventually my MS at Berkeley in sanitation and disease. I only knew about toxicology through community organizing with North Carolina farm workers; I never thought I’d work in toxic chemicals.
Q. Rashmi, what do you do at Earthjustice?
Rashmi: I work with a team of lawyers to hold regulatory agencies, mostly the EPA, accountable for protecting people and the environment from toxic chemicals. My work largely involves identifying scientific gaps in chemical risk evaluations and working with partners to find ways to fill these gaps. It also involves scrutinizing agency actions to see if the agency has relied on the strongest science and interpreted it appropriately. I draft comments on agency proposals, coordinate expert testimonies for legal cases, synthesize and translate scientific material for use in legal advocacy, and advocate issues through blog posts, op-eds, or reports. We work a lot with PRHE, which conducts important research to fill scientific gaps. Environmental justice is also an important part of my work, especially in figuring out how to make the strongest scientific case for the agency’s duty to protect communities living near polluting facilities from toxic exposures.
Q. We’ve talked a lot about TSCA on this blog. What is the most important thing you think people need to know about TSCA?
Swati: What I keep front and center about amended TSCA is that it came after decades of limited to no meaningful change. The purpose of original TSCA was to improve conditions and deal with unchecked widespread industrial pollution. Russell Train, the third EPA administrator, said TSCA was “one of the most important pieces of preventative medicine legislation,” and he said this in 1976, but for decades TSCA failed because it was undercut by the industries it was supposed to regulate.
Rashmi: TSCA provides an important opportunity to better protect people from exposure to toxic chemicals from manufacture to disposal. With the 2016 TSCA amendments, we now have more ways to hold EPA accountable for ensuring that toxic chemicals don’t harm people or the environment. The amendments enacted by Congress are not perfect, but if properly implemented may lead to better protections for people who are exposed, especially if they are at greater risk of harm due to their age, underlying disease, or psychosocial stress. The Trump Administration’s EPA routinely violated the law, ignoring communities’ exposure to toxic chemicals in the air and water, failing to account for some of the most sensitive health effects, and even ignoring the advice of science advisors. With a new administration that says it is committed to scientific integrity, we are hopeful that TSCA will be used to actually protect people from harmful chemicals.
Max: From the scientist’s perspective, I investigate complex mixtures of environmental contaminants and it takes years of training to do those analyses and even with all that training and bio-statistics tools, you’re just grazing the tip of the iceberg of widespread environmental contamination. What is so important about TSCA is the opportunity to help scientists access the right data on toxic chemicals and historically it’s fallen short; access to data is something we’re going to have to keep pushing to better equip scientists with the proper data so we can protect public health.
Q. On that note, how can EPA better protect people from toxic chemicals?
Rashmi: EPA can start by adopting a precautionary approach when assessing the risk of toxic chemicals. This means prioritizing information gathering for chemicals of concern early in the risk evaluation process, relying on scientifically sound methodologies for systematic review, factoring human variability and vulnerability into risk calculations, and considering exposures to multiple chemicals from multiple sources. This will result in risk determinations that are more protective of people and the environment.
Max: The data gap issue is huge. If there are major data gaps on chemicals, we need to be asking manufacturers to provide that data or fund the collection of more data. Data collection needs to be expanded and more publicly available and accessible.
Swati: There’s also the issue of confidential business information and what industries are allowed to declare. Industries have claimed things such as health and safety data or chemical identities as trade secrets or confidential business information, but they are very relevant to health and particularly to fenceline communities. That creates a data scarcity where there is none and then EPA up to this point has taken that lack of data to mean lack of risk.
Q. Swati, you helped spearhead recommendations to strengthen EPA and TSCA, one of which was to regulate chemicals as a class. What does that mean and why is it important?
Swati: EPA’s process until right now is to look at chemicals one at a time; considering the number of chemicals in the environment and on the market, it’s just not plausible to look at them one at a time. Many of them are structurally similar and industries create a lot of chemicals that function similarly, e.g., making something non-stick (PFAS) or making plastic bendy (phthalates) or hard (bisphenols). Scientists have come up with “read across” approaches, looking at similar toxicology profile – e.g., they all target your liver and shut it down – to manage this seemingly insurmountable number of chemicals on the market. The purpose of looking at chemicals as a class is to get away from this ineffective and scientifically inaccurate way of looking at chemicals and there’s also language in TSCA about chemical groupings. This approach helps to avoid regrettable substitutions or when industry makes a mild alteration and calls it a different chemical, but it still causes cancer or harms your air or muddies your water. If it walks like a duck, talks like a duck, it’s a duck.
Q. Max, how did your research on endocrine disrupters and maternal/child health lead to a shift in thinking about regulating one chemical at a time to regulating by class?
Max: I started by investigating one chemical at a time. That’s what a lot of my colleagues were doing because that was where the scientific training was at the time. Our methods were evolving as I was earning my PhD. We published this paper on phthalates and we saw they were associated with higher odds of delivering preterm but then when we aggregated multiple phthalates together – looked at the cumulative effect – there was an even more pronounced risk of preterm birth. So that led us to aggregate chemicals on the total effect. It’s not adequate to look at individual chemicals as the full picture of the risk profile – and that is just on the outcomes side. A lot happens between exposure to outcome – inflammation, cardiovascular irregularities, liver changes – it’s an incredible path these chemicals take and it’s our task to untangle these relationships so we’re trying to figure that out by looking at these complex intermediate pathways.
Q. There has been a lot of focus on environmental justice recently. How can we fix the injustice that some communities face who live in fenceline communities?
Rashmi: The chemical industry should be held accountable for the harm it has inflicted on nearby communities. While we don’t have all the answers to correct this injustice, science is part of the solution. Robust studies examining chemical exposures in areas surrounding polluting facilities will help us to identify communities that are disproportionately burdened by chemical exposures. EPA can then use these data to inform chemical risk assessments and cumulative risk assessments. Using coordinated scientific approaches to expand our understanding of the harms fenceline communities face will ultimately improve our ability to manage chemical exposures in these communities and break the toxic cycle of environmental injustice.
Max: We need to integrate tools into the communities that need it. We’re working on developing evidence-to-decision frameworks and science/policy communication tools that can be shared with communities to promote systemic change at the local, state, and federal levels to address historic trends of environmental injustice.
Swati: Somebody made a choice to put polluting facilities in an area where Black and brown people live because they knew they would have limited push-back and could spin environmental pollution as economic opportunity with little oversight to make a very quick and very big buck. Thus far, we have relied on institutions that lack first-hand experience and industries that created the problem for solutions, and that has alienated the needs of people and communities who experience disproportionate amounts of pollution and the adverse health effects that come with it. The solution is with the communities on the ground and recognizing their inherent expertise. It’s great that the current Administration and EPA are focused on racial and environmental justice, but I’m still waiting to see how EPA meaningfully engages in this work. After decades of allowing harm to predominantly Black, brown, indigenous, and low-wealth communities, these folks need more than nice words. EPA needs to support and resource community leadership and decision-making to make sure we are meeting the needs of communities on their terms, and researchers and scientists need to use our expertise to empower communities and community leaders. At the bare minimum, that is the first of many steps toward justice.
APHA Session 2028.0: Emerging Environmental Leaders Panel: Using the Toxic Substances Control Act (TSCA) to Create the Healthiest Nation and Promote Environmental Justice
Sunday, October 24, 2021
2:00 – 3:30pm
Program: Environment
To mark the 5-year anniversary of the bipartisan legislation called the Frank R. Lautenberg Chemical Safety for the 21st Century Act, emerging young leaders will reflect on the opportunities to create the healthiest nation by addressing harmful chemical pollution. This reform law was designed to modernize U.S. industrial chemical policy to promote health and keep pace with new science and reforms in Europe. The law will shape the environmental field in coming years and new leaders are stepping up for the challenges ahead.
Co-host: Margaret Willis, Texas Department of State Health Services
Moderator: Patricia Koman, University of Michigan
Impact of endocrine active chemical exposures on maternal and child health
Max Aung, PhD, MPH, University of California San Francisco, San Francisco, CA
Using science to promote environmental justice under the lautenberg act
Rashmi Joglekar, PhD, Earthjustice, New York, NY
From science to solutions: Engaging health professionals in policy to address toxic chemicals and protect public health into the future
Swati Rayasam, MSc, University of California San Francisco, San Francisco, CA
Fifth anniversary of the lautenberg amendments to the toxic substances control act (TSCA) and opportunities to create the healthiest nation
Patricia Koman, MPP, PhD, Swati Rayasam, MSc, Max Aung, PhD, MPH, and Rashmi Joglekar, PhD
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