What happened: As the Environmental Protection Agency (EPA) assesses ten priority chemicals for their harms to human health and the environment, the agency has announced during a public meeting that its Scientific Advisory Committee on Chemicals (SACC) has been restricted from offering certain types of science-based criticism. Specifically, the EPA has forbidden SACC from commenting on some of the EPA’s decisionmaking processes which have a scientific basis, such as certain routes of exposure, worker safety protections, cancer risks, and the quality of industry data.
Why it matters: Scientific advisory committees are explicitly designed to ensure that the EPA uses the best available science and methods, and the inability of scientists to improve upon the way we assess chemicals could result in weaker standards that would fail to protect us from known health risks. Considering that SACC was asked to carry out peer reviews of the EPA’s draft risk assessments on ten potentially deadly chemicals (which include asbestos and the flame retardant HBCD), they should be allowed to provide science-based criticisms on potential flaws in these drafts.
By claiming that they are “policy decisions,” the Environmental Protection Agency (EPA) has restricted its Scientific Advisory Committee on Chemicals (SACC) from providing important scientific input while the agency reviews the dangers of ten priority chemicals under the Toxic Substances Control Act. However, members of the scientific community, such as the American Public Health Association, have been critical of the agency’s approach to assessing the chemicals, particularly the EPA’s attempts to ignore the numerous ways that people are exposed to these chemicals. For the first few peer reviews, the scientists serving on SACC voiced similar concerns during the committee’s public meetings. However, as reported by the Environmental Defense Fund, the EPA has claimed at a September 2019 SACC meeting that these concerns fall under “policy decisions” and therefore should not be evaluated by the SACC scientists. This is a false claim – decisions on issues like exposure routes are based on science, not policy.
Because of this decision, SACC is unable to provide scientific input on key science-based decisions that will undoubtably affect how the chemicals’ harm to public health and safety are being evaluated by the EPA. One of the issues that SACC cannot provide input on is how the EPA is currently failing to consider several important ways that people are exposed to chemicals in their everyday lives. In particular, the EPA is ignoring exposures from air emissions, drinking water, and waste products from its analysis, an action that we at the Union of Concerned Scientists previously considered an attack on science.
There are also concerns that the EPA’s risk assessments make unrealistic assumptions, like that all workers will don personal protective equipment (like gloves or a respirator) for the entirety of the work session and that the equipment will be effective at all times. This assumption violates one of the basic scientific tenants that underlies occupational safety, the National Institute for Occupational Safety and Health’s “hierarchy of controls,” which states that personal protective equipment is one of the least protective measures against a hazard and it could result in workers being exposed if the equipment fails.
SACC is also unable to address the EPA’s decision to loosen longstanding standards that determine when a cancer risk is too high. Finally, the committee cannot comment on the EPA’s failure to use its authority to request recent and robust health information; instead, the EPA is relying on older industry data that was collected on a voluntary basis and that is of indeterminant quality.
Unfortunately, it is a well-established trend at the EPA under the Trump administration to undermine chemical safety and sideline advisory committees. EPA officials are suppressing chemical toxicology studies generated by the EPA’s Integrated Risk Information System program, including a report on formaldehyde; they previously helped bury a CDC report on PFAS; and they failed to ban asbestos, a substance that is especially harmful to human health. EPA officials have also dissolved a scientific advisory committee that looked at particulate matter air pollution, which concerned members of the disbanded committee enough that they independently gathered one year later to review the science. The science of assessing a chemical for potential harm should be a thorough and rigorous process. The EPA’s attempts to forbid the well-respected scientists of SACC from conducting a full and comprehensive peer review is unsettling, and the American people will face the brunt of the harms for these actions.