The agency excludes animals and deprioritizes co-exposures. We can do better.
Patrick Masseo in the Environmental Health News
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.
Patrick Masseo is a former senior advisor
for health policy in the New York City Mayor’s Office from 2019 to 2022 and a
doctoral student in public health at SUNY Downstate Health Sciences University.
Views expressed in this piece are those of the author and not necessarily those
of Environmental Health News or its publisher, Environmental Health Sciences.