Opinion: Two flaws in how the U.S. EPA wants to assess hazardous chemical groups
The agency excludes animals and deprioritizes co-exposures. We can do better.
Calls for rail reform after the East Palestine train derailment overlook a more fundamental policy issue: The need for stronger regulations on the hazardous materials that infuse our products and saturate our lives.
More than 80,000 chemicals are registered for commercial use with the U.S. government. Tens of thousands of these have never been assessed for public health risk or impact. Worse, there is nearly no knowledge or measure of how the millions of potential chemical group co-exposures endanger our human health and fellow living species.
The U.S. Environmental Protection Agency is taking slow, irregular and flawed steps to assess risk. The latest steps, building on a 2003 framework, are up for public comment – yet to date the announcement has drawn 497 views on the Federal Register website and just 10 comments, four of which were posted April 20 by the same person representing four different chemical consortiums asking for a deadline extension.
The public comment period is scheduled to close Friday, April 28, and I urge you to make your voice heard.
Cumulative risk assessment
The agency seeks comment on three facets: Cumulative risk assessment principles, approach for risk assessment of phthalates, and a slate of candidates for an advisory panel guiding the process. Together these principles and committee members will have tremendous power and decision-making influence over the environment of billions of living animals, plants and humans.
The other six public comments focus just on the candidates, skipping over seemingly bland – yet important! – bureaucratic principles and assessment approaches. Focusing on the proposed principles of cumulative risk assessment, the document describes:
- Priority populations
- Types of stressors
- Route of exposures
- How cumulative chemical groups will be defined for assessment.
Include animals, plants and other organisms
As a former senior advisor for health policy in the New York City Mayor’s Office and a doctoral student in public health at SUNY Downstate Health Sciences University, I strongly urge the EPA to reconsider two structural flaws of their proposed principles:
First, the principles must be rewritten to include plants and animals in cumulative risk assessments of chemical groups.
The history of environmental health is a repetitive one, where hazards, risks and impacts are first identified among plants and animals. In the 19th century, the adaptation of peppered moths to their polluted environment was an early influence on evolutionary theory – the white and black moths gradually became mostly black to better blend into a sooty environment.
Amidst the Minamata Bay disaster in the 1950s, where a factory dumped large quantities of mercury into the water, the first signals of environmental health danger were erratic behavior among cats. In East Palestine, Ohio, numerous reports already describe thousands of domestic and wild animals dying.
Partly because of their shorter lifespans and reproduction cycles, cumulative risks – including intergenerational impacts – can be more quickly and thoroughly identified in plants, animals and other organisms than by studying humans.
Plus omitting animals is an inhumane violation of the inherent natural rights and dignity due to our fellow Earthlings. EPA claims plants, animals and other organisms are left out because of a lack of related guidance documents, which is indicative of a larger unacceptable reality of chemical regulation. This is dooming an unknown number of living species to unknown dangers causing unknown harm.
Prioritize real-world exposures
The second structural flaw is how EPA prioritizes chemical groups for assessment.
Considering EPA’s perpetually limited resources and strained enforcement mechanisms, risk assessments of chemical groups should be identified and prioritized by real world co-exposure considerations. This approach better reflects the “ifs” and “whens” we come into contact with in a cumulative chemical group.
This reduces the likelihood of industrial companies clogging the assessment pipeline with chemical groups that we would likely never see.
Unfortunately, we will experience more chemical train derailments, toxic spills into our water table, unfettered air pollution from chemical production and other industrial catastrophes in the United States.
As documented in the Pulitzer Prize-winning book, Toms River by Dan Fagin, the US government could do little in the late 20th century to assess the cumulative impact of different chemicals contaminating groundwater or air. Some 50 years later, our government still lacks a thorough and adequate process to conduct assessments of, and to collect critical information about, the cumulative risk and impact of co-exposures such as vinyl chloride via air pollution and dioxins through groundwater contamination that are occurring today in East Palestine.
To better regulate the production, transportation and destruction of chemical groups we must know all of the risks. Ignoring the mistakes of the past places our health – and the health of our fellow living beings – in peril.
The EPA must update its Proposed Principles of Cumulative Risk Assessment Under the Toxic Substances Control Act to include animals and prioritize co-exposures for cumulative risk.