Tracey J. Woodruff testifies before Congress

PRHE’s Director, Dr. Tracey Woodruff, testified before Congress on Oct 18, 2023 at a hearing of the House Energy and Commerce Subcommittee on Environment, Manufacturing and Critical Materials on EPA’s efforts to regulate ethylene oxide (EtO). She was one of four witnesses at the hearing; two were CEOs of the country’s largest chemical companies and the third was CEO of the chemical industry trade group. Tracey was the only woman, only scientist, only PhD, and only person defending people’s health on the panel.

Following is the oral testimony she gave at the hearing. A link to video of her testimony is below.

Congressional Testimony before the House Energy and Commerce Subcommittee on Environment, Manufacturing, and Critical Materials

October 18, 2023

Chairwoman McMorris Rodgers, Chairman Johnson, and Ranking Members Pallone and Tonko, thank you for the opportunity to testify. I am Dr. Tracey Woodruff, a professor from the University of California, San Francisco and director of the Program on Reproductive Health and the Environment and the EaRTH Center. We conduct research to understand how industrial chemicals and environmental pollutants impact people’s health.

Toxic chemicals take a measurable toll on people’s health.

Toxic chemicals are widespread in our air, water, food, homes and workplace and consequently exposures begin before birth and continues throughout life. We know these exposures take a measurable toll on people’s health and can increase the risk of cancer, infertility, asthma, neurological disease, cardiovascular disease, and multiple adverse impacts on child development,[1],[2]

Environmental regulations came about from necessity. Before EPA was established and laws including the Clean Air Act and the Clean Water Act were enacted, toxic waste and chemicals were literally dumped into our air and water unchecked. Pictures of cities like New York or Pittsburgh before and after the 1970s show a stark improvement.

Environmental regulations have cleaned the environment while the economy has grown.

Here is the great news. Environmental regulations and a clean environment are good for people’s health AND the economy. Since 1970, environmental regulations led to a 78% decrease in 6 different air pollutants while at the same time our GDP increased 304%.[3] This success is due to both environmental regulations and American innovators.

Environmental regulations are innovation generators – resulting in new businesses, new jobs, and new products safer for consumers, workers, and communities. EPA regulated formaldehyde in pressed wood products[4] after it was discovered formaldehyde was harming people living in trailers after Hurricane Katrina and the manufacturing of formaldehyde-free pressed wood products increased. The soy-based adhesive industry, which has manufacturers in the U.S., is predicted to grow almost 8% a year,[5] which also economically benefits U.S. soybean farmers.[6]

Health benefits of environmental regulations

Environmental regulations also produce enormous societal benefits from reduced health problems. OMB reported that over a 10-year span the annual benefits to the American public of EPA major rules ranged from $194 billion to $687 billion per year; almost all from reduce health risks due to lowered pollutant emissions and far outweighed estimated costs.

As another example, EPA’s recent proposed drinking water regulation for six PFAS would provide health benefits as high as $2 billion every year and represents an important step forward in addressing the health risks of forever chemicals.[7]

Americans want safe products

In a recent nationwide public opinion survey, over 90% of voters – including Republicans, Democrats, and Independents – agreed the federal government should require products be proven safe before companies are allowed to put them on the market, and it is important for companies to keep harmful chemicals out of everyday products – even if it increases the cost.

TSCA and its importance to health of Americans

Congress updated the Toxic Substances Control Act, or TSCA, in 2016 to ensure EPA did a better job of protecting susceptible populations like pregnant women, children, workers, and people living in proximity to clusters of polluting facilities from harmful chemicals.

But because our system to regulate toxic chemicals has allowed companies to put products into the marketplace before we are sure they are safe and allowed companies to release known toxic chemicals into the environment, we continue to see problems like the widespread PFAS contamination crisis and fenceline community exposures to dangerous levels of carcinogens, like ethylene oxide.

Ethylene oxide

In 2016, after extensive external peer review, and public comment, EPA concluded ethylene oxide inhalation is “carcinogenic to humans.” Studies also find ethylene oxide associated with neurological, respiratory, and reproductive harm.[8],[9] Multiple communities in the U.S., often low income and communities of color, are exposed to dangerous levels of ethylene oxide from sterilization facilities.[10] EPA now has an opportunity to significantly reduce exposures to cancer-causing EtO by issuing a necessary update to its emissions standard for sterilization facilities.

I know you have witnesses here today representing industries concerned about the regulation of EtO and other chemicals. It is important to hear from all affected stakeholders, however it is also critical we prioritize health in environmental regulations and use science free of financial conflicts of interest (COI), or bias toward the industries that may have a vested financial interest in minimizing EPA’s regulation. I encourage you to read our recent paper, The Devil They Knew, which analyzes internal industry documents from PFAS manufacturers and shows the industry knew about PFAS health harms decades before the public.[11] This is a small example of our work to make transparent how financial interests can undermine public health interests. It also demonstrates why it is essential to have a strong EPA, using the best scientific methods to help protect people and communities from the impacts of harmful chemicals, which, in turn, ensures a strong economy.

[1] Diamanti-Kandarakis, E., Bourguignon, J. P., Giudice, L. C., Hauser, R., Prins, G. S., Soto, A. M., . . . Gore, A. C. (2009). Endocrine-disrupting chemicals: an Endocrine Society scientific statement. Endocr Rev, 30(4), 293-342. doi:10.1210/er.2009-0002

[2] US Environmental Protection Agency. (2011). Benefits and Costs of the Clean Air Act Amendments 1990-2020, the Second Prospective Study. Availble:

[3] US Environmental Protection Agency. (2011). Benefits and Costs of the Clean Air Act Amendments 1990-2020, the Second Prospective Study. Availble:

[4] 15 U.S.C.§2697

[5] Grand View Market Research. Wood Adhesives Market Size, Share & Trends Analysis Report By Product (Urea-formaldehyde, Soy-based), By Application (Flooring, Furniture), By Substrate, By Region, And Segment Forecasts, 2023 – 2030. Available:

[6] (2020, May 13). Performance and Sustainability: Soy-Based Adhesives and Sealants Excel in Wide-Ranging Applications. ASI Adhesives & Sealants Industry. Retrieved October 17, 2023, from

[7] U.S. EPA.  PFAS National Primary Drinking Water Regulation Rulemaking.  March 29, 2023.  88 FR 18638.  Table 66.

[8] Toxicological Profile for Ethylene Oxide. Atlanta (GA): Agency for Toxic Substances and Disease Registry (US); 2022 Aug. Chapter 2, Health Effects. Available from:

[9]USC Environmental Health Centers. (2023). Infographic: Ethylene Oxide. Available:

[10] Union of Concerned Scientists. (2023). Invisible Threat, Inequitable Impact. Available:;

[11] Gaber, N., Bero, L., & Woodruff, T. J. (2023). The Devil they Knew: Chemical Documents Analysis of Industry Influence on PFAS Science. Annals of global health, 89(1), 37.