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EPA on the Right Track for Addressing Endocrine-Disrupting Chemicals, but Should be Wary of Potential Detours

A year ago this month, CPR published a white paper that laid out a two-phased action plan for federal agencies to take some critical steps toward protecting the public from Bisphenol-A (BPA). The report provided both short-term and long-term action items for the EPA, FDA, and OSHA that could establish stronger safeguards, risk assessment practices, and warning mechanisms for families and consumers concerning BPA and other endocrine-disrupting chemicals.  We said an underlying requirement for both short-term and long-term action items is for federal agencies to acknowledge the unique low-dose effects and non-monotonic dose response curves (NMDRC) of endocrine-disrupting chemicals and adapt existing scientific protocols to reflect these unique risks.

Shortly before the conclusion of 2012, EPA announced a promising new effort in turning these action items into a reality.  The agency is forming a working group dedicated to investigating and analyzing low-dose effects and NMDRCs for endocrine disrupting chemicals, and intends to release a “state of the science” paper, which will undergo peer review and “help inform how the safety of chemicals are assessed.”  The working group will focus on three critical questions in conducting its work:

  • Do NMDRCs capture adverse effects that are not captured using our current chemical testing strategies (i.e. false negatives), and are there adverse effects that we are missing?
  • Do NMDRCs exist for chemicals, and if so under what conditions do they occur?
  • Do NMDRCs provide key information that would alter EPA’s current weight of evidence conclusions and risk assessment determinations, either qualitatively or quantitatively?

While the mounting evidence concerning BPA and other endocrine-disrupting chemicals (including this thorough scientific review and study released in March of 2012 and credited with spurring EPA’s initiative) would answer each of these questions in the affirmative, this small but meaningful movement toward improving how our federal government determines what chemicals are safe deserves encouragement and support.

Assuming EPA’s working group does answer these questions affirmatively, EPA’s initiative should not stop there, and it should forge ahead with the next steps that can turn the state-of-the-science paper into actual change.  Two potential next steps are developing guidance that instructs risk assessors on how to account for these low-dose effects and NMDRCs, and improving Integrated Risk Information System (IRIS) evaluations.  Additionally, EPA can continue the long-term trudge forward in ultimately drafting new rules and underlying protocols that permanently integrate low-dose effects and NMDRCs into the established risk assessment framework. 

But EPA must also be wary of unnecessary detours and obstacles.  Industry protests and influence at all levels of the process can easily stall EPA’s progress, as was seen with EPA’s report concerning chemical dangers for children.  In the spirit of the New Year, I encourage EPA to keep its resolve to take these important steps forward and change the way we evaluate endocrine-disrupting risks – all with a mind toward protecting the public.

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Aimee Simpson | January 8, 2013

EPA on the Right Track for Addressing Endocrine-Disrupting Chemicals, but Should be Wary of Potential Detours

A year ago this month, CPR published a white paper that laid out a two-phased action plan for federal agencies to take some critical steps toward protecting the public from Bisphenol-A (BPA). The report provided both short-term and long-term action items for the EPA, FDA, and OSHA that could establish stronger safeguards, risk assessment practices, […]

Robert Verchick | January 4, 2013

The Long Goodbye: On Seeing the Sundarban Islands

The Ganges River begins at the foot of the Gangotri Glacier in the Himalayas and culminates at the Sundarbans Delta, a massive sprawl of swamps, lakes, and scores of islands. (Find an earlier post on the Ganges here.) It’s the largest river delta in the world—home to endangered Bengal tigers, miles of mangroves, and nearly […]

Matthew Freeman | December 27, 2012

Using Executive Orders to Move the Agenda

CPR’s Rena Steinzor and Amy Sinden have an op-ed in this morning’s Baltimore Sun urging President Obama to make aggressive use of Executive Orders leading to regulation action to protect health, safety and the environment.  They write: Barack Obama‘s ambitions are clear. He came to office in 2009 on the strength of a far-reaching, progressive […]

Daniel Farber | December 21, 2012

D.C. Circuit Denies Rehearing in Endangerment Case

Cross-posted from Legal Planet. Six months ago, the D.C. Circuit upheld EPA’s finding that greenhouse gases endanger human health and welfare, triggering coverage under the Clean Air Act.  On Thursday, the full court denied rehearing to the three-judge panel’s decision.  There were only two dissents, which obviously were hoping to set the stage for a cert. petition […]

Robert Verchick | December 18, 2012

Sweating the Small Stuff: Indian Villages Plan for Climate Change

In October, I wrote about the city of Surat, the diamond-polishing capital of India, and its battle against climate change.  Recently I had the chance to visit another municipality working on adaptation, a place known more for its postage stamp farms and wandering livestock than jewelry and textiles. It’s called Gorakhpur, and is located in […]

Thomas McGarity | December 17, 2012

Mercatus Center OSHA Report Rehashes Discredited Free Market Nostrums

This post was written by Member Scholar Thomas O. McGarity and Senior Policy Analyst Matt Shudtz. The Mercatus Center has recently published a report on OSHA that simply rehashes the same old discredited arguments that industry apologists in academia and think tanks have been making for thirty years.  Not surprisingly, they reach the conclusion that […]

Amy Sinden | December 14, 2012

AP Says Administration ‘Unleashes New Rules;’ Mostly Finds Examples of Rules Not Unleashed

Cross-posted from ThinkProgress. “Election over, administration unleashes new rules,” trumpeted an Associated Press story this week. What are these newly unleashed rules? Perhaps the big food safety rules that have been stalled for more than a year have gone through? Rules limiting greenhouse gas emissions from new and existing power plants? Long-awaited rules to protect coal miners’ safety? […]

Holly Doremus | December 14, 2012

Jane Lubchenco’s Legacy at NOAA

Cross-posted from Legal Planet. NOAA administrator Jane Lubchenco has announced that she will leave her post at the end of February. Her letter to NOAA employees, reprinted in the Washington Post, cites the difficulty of maintaining a bi-coastal family life. Dr. Lubchenco, a distinguished marine biologist, has put in four years at the helm of […]

Daniel Farber | December 13, 2012

Mayans! Apocalypse! Climate Change!

Cross-posted from Legal Planet. Mayan apocalypse: panic spreads as December 21 nears Fears that the end of the world is nigh have spread across the world with only days until the end of the Mayan calendar, with doomsday-mongers predicting a cataclysmic end to the history of Earth. That’s from a British newspaper, the Telegraph, but […]