Continuing their crusade to undermine the Integrated Risk Information System (IRIS), the most prominent worldwide database of toxicological profiles of common chemicals, House Republicans held yet another hearing Thursday morning to review how the Environmental Protection Agency’s (EPA) chemical risk assessment program interacts with and informs regulatory policy. This time, witnesses descended from politics into the weeds of science policy, doing their best to pretend that scientific risk assessments that say how “safe” dioxin is or isn’t have the same supposedly “job-killing” impact as all those actual environmental, health and safety regulations they’ve been maligning for the past year.
The witnesses, a peculiar mix of industry-funded scientists and hostile state regulators, were united by the fact that they don’t seem to know the difference between a straightforward scientific assessment of the potential risks of chemicals, and a regulation to do something about those risks. IRIS provides the former – scientific assessments of risk. Once those assessments are completed, regulators can get to work weighing the costs and benefits of diminishing whatever risks the chemicals pose, and perhaps promulgating a regulation. The honest scientific assessment is a starting point. Industry wants to characterize IRIS risk assessments themselves as regulations in a blatant attempt to slow and weaken the risk assessment process.
Michael Honeycutt, of the Texas Commission on Environmental Quality, provided testimony that was largely concerned with public perception of EPA risk assessments and the potential impacts of risk assessments on future remediation efforts. Honeycutt’s concern about public perception and remediation would be more fruitfully directed at those agencies and regulations designed to consider such possibilities in the decision-making process, such as the Food and Drug Administration for his food safety examples and the Comprehensive Environmental Response, Compensation, and Liability Act for standards required by remediation efforts.
Jerry Cook, Chief Technological Officer of Chemical Products Corporation, also conflated risk assessment and regulation. He used his testimony as a forum to impugn the EPA. Cook’s primary focus was barium, no surprise given that he is employed by a barium producer and depends on the substance for his livelihood. However, even Cook took no issue with EPA’s current IRIS risk assessment for barium. Rather, he voiced frustration that the most recent IRIS assessment has yet to be rolled into regulations promulgated under RCRA. This by no means a criticism of IRIS, and is in fact evidence of IRIS efficacy.
David Dorman, a professor of toxicology at North Carolina State University, provided testimony on the already much discussed National Academy of Science (NAS) review of the IRIS-generated formaldehyde risk assessment. His primary concern is not with EPA’s science or the IRIS process. Instead, Dorman found fault with the length of the resulting draft assessments and the apparent lack of consistency with which section syntheses and end-of-section conclusions appear in the report. This perceived shortcoming is easily remedied and does little to cast doubt on the efficacy of IRIS as a risk assessment tool.
Harvey Crewell, a career industry consultant, relied heavily on an Office of Management and Budget (OMB) memorandum during his testimony before the subcommittee that argued that the EPA should include alternative, non-linear, dose-response curves in its IRIS assessments which would allow industry to claim that greater exposure does not translate to greater risk. This OMB document, however, originated in 2006 as a bulletin for risk assessment for federal agencies. The OMB sent this bulletin to the NAS for review and was immediately told to go back to the drawing board. Thus, Crewell cited a non-binding, non-peer-reviewed memo that constitutes little more than the opinion of OMB staff from five years ago. The EPA’s current policy, on the other hand, was developed by scientists and has been thoroughly peer reviewed.
IRIS risk assessments and any regulations that may eventually flow from them are two entirely different things, and ought to remain so. Conflating risk assessment and regulation in an attempt to slow and confuse the risk assessment process, as all four of these witnesses have done, pulls the rug out from under sound science and threatens the health and safety of all. Indeed, a gutted and ineffective IRIS program might even provide a false sense of security while providing little to no actual protection. This, of course, is what industry wants and is tirelessly working toward, including Thursday’s hearing.