Holding EPA accountable for its scientific methods

House Committee on Science, Space & Technology Chair Rep. Eddie Bernice Johnson sent a letter to EPA chief Michael Regan asking the Agency when it will update its systematic review methodology – the method used to evaluate chemicals risks – under the Toxic Substances Control Act (TSCA).

PRHE has been working to ensure EPA uses validated systematic review methods since 2018 because the methods used to evaluate the science influence the decisions made under TSCA and ultimately the public’s health.

TSCA requires that chemical evaluations of the science must be consistent, transparent, and health protective. Unfortunately, in 2018, EPA adopted a systematic review methodology under TSCA for evaluating the science on environmental chemicals that essentially allowed them to exclude studies in the risk evaluations. For example, EPA ignored evidence that TCE harmed children’s brains and that methylene chloride killed workers.

Our team has monitored EPA’s actions under TSCA and informed the National Academies of Sciences, Engineering, and Medicine (NASEM) report that identified alarming deficiencies in the 2018 systematic review methodology. The NASEM report recommended EPA adopt a systematic review method like the one PRHE developed years ago – or similar. However, EPA has failed to demonstrate that they are adhering to these recommendations, so we have been highlighting our concerns about how this lack of compliance threatens the validity of EPA’s current risk assessments under TSCA.

As Rep. Johnson stated in her letter:

Several of the problems that the National Academies identified in the 2018 Systematic Review were reminiscent of the Agency’s pernicious ‘Strengthening Transparency in Regulatory Science’ rule. The Science Committee spent the better part of a decade working to prevent this dangerous proposal from becoming either law or Agency policy because it would have systematically suppressed epidemiological studies that are critical for understanding environmental hazards and protecting public health, while allowing Agency staff to eliminate ’inconvenient’ research findings on an arbitrary basis.

The letter also identifies PRHE’s method as one important option for EPA to consider:

As the National Academies recommended, there are existing, widely recognized, peer-reviewed methods for systematic review that have been tested over time, including those promulgated by the University of California San Francisco’s Program on Reproductive Health and the Environment (PRHE).

Rep. Johnson’s letter is an important step in holding EPA accountable to the law and its mission to protect health and the environment. We will continue to monitor EPA’s approach to systematic review to ensure that science and health are prioritized at EPA.

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