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EPA Releases IRIS Assessment of Dioxin Non-Cancer Risks

Today EPA released the first part of its long-awaited reassessment of the human health risks posed by 2,3,7,8-tetrachlorodibenzo-p-dioxin, a chemical considered to be the most toxic of the dioxin compounds and the stuff that made Agent Orange so bad for its victims.  It’s bittersweet news: on the one hand, the decades-long stretch between EPA’s first look at dioxin and this document is something we don’t like to see, while on the other, today marks an enormous step forward. The document released today focuses only on non-cancer effects and sets an oral reference dose—the level of exposure below which key health impacts are unlikely to occur.  Past EPA assessments looked only at dioxin’s carcinogenic risks, so it is an important development that today’s release looks at the many other adverse health outcomes that might occur, such as “chloracne, developmental and reproductive effects, damage to the immune system, interference with hormones, skin rashes, skin discoloration, excessive body hair, and possibly mild liver damage.”

As Ben Somberg noted here in December, the American Chemistry Council tried to convince EPA that a rider to the FY2012 omnibus spending bill required the agency to pull back the dioxin assessment.  CPR President Rena Steinzor and I wrote a letter to EPA Administrator Lisa Jackson to correct the record on ACC’s false claim.  The letter explained how the House had earlier considered a version of the bill that required EPA to rework all draft and final IRIS assessment due out in FY 2012, but ultimately went with a bill that requires revision of only the draft assessments and not the final assessments.

Good for EPA for calling the chemical industry’s bluff!

The most important part of EPA’s dioxin risk assessment is still in the works.  The cancer-focused part of the assessment continues to be under review.  The National Academy of Sciences undertook a two-year review of EPA’s draft dioxin assessment (both the non-cancer and cancer analyses) in 2004-2006.  There’s no question that dioxin is a carcinogen.  This protracted fight over the cancer part of the assessment revolves around exactly how dioxin and related compounds cause cancer.  It matters because the mode of action determines the shape of the dose-response curve, which will ultimately impact EPA’s best guess as to the “safe” level of dioxin exposure.  The lower the level, the more expensive Superfund cleanups become and the more likely it is that guidelines for meat and dairy consumption will have to be rethought.  (Dioxin bioaccumulates in fat, resulting in the public’s primary routes of exposure being beef, dairy, and freshwater fish consumption.)

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The Age of Greed: Science Drowned by Politics

Last week, a reporter asked me, “How’s science doing these days?,” “Science” is an impossibly big category, of course, but the answer was easy: “Badly,” I said.

Exhibit number one is climate change. The frightening truth is that no fewer than 84 percent of scientists in this country surveyed by Pew say that the earth is warming because of human activity; 70 percent describe the problem as “very serious.” Although much is made of the supposed “dissenters” on the issue, no one with any educated familiarity with the subject doubts that the vast—and I mean virtually all—scientists with meaningful credentials to understand the subject agree that precipitous climate change is happening and that curbing human-generated carbon emissions must be done to avert disasters so grave we can barely imagine them. Human beings have a hard time making sacrifices today to avert problems that seem remote, but the public’s ambivalence on this subject is reinforced by a steady and effective public relations campaign by fossil fuel companies to make the science of climate change seem fraught with doubt.

I am not willing to argue here that if we could only get the scientific truth straight, we could gallop across the tundra and solve this problem. How to apportion responsibility for sharply decreasing emissions between the developed and developing world is a challenge that may be the toughest we have ever faced. Not only do we lack the policymaking framework for negotiating such changes, but decades of flawed energy policies have hindered and continue to hinder the development of available and affordable solutions. But as long as we are stuck on the science—denying the consensus, elevating the few deniers to a position of equal authority as the well-informed—the short-term, self-serving concerns of a few trump the urgency of the problem for the many.

What leadership can we expect from politicians of both parties as we embark on contentious, high-stakes electoral season?

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Reclaiming Global Environmental Leadership

For more than a century, the United States took the lead in organizing responses to international environmental problems.  The long list of environmental agreements spearheaded by the United States extends from early treaties with Canada and Mexico on boundary waters and migratory birds to global agreements restricting trade in endangered species and protecting against ozone depletion.  In the last two decades, however, U.S. environmental leadership has faltered. 

The best-known example is the lack of an effective response to climate change, underscored by the U.S. decision not to join the Kyoto Protocol.  But the attention climate change receives should not obscure the fact that the United States has also failed to join a large and growing number of treaties directed at other environmental threats, including marine pollution, the loss of biological diversity, persistent organic pollutants, and trade in toxic substances. 

Today CPR publishes Reclaiming Global Environmental Leadership: Why the United States Should Ratify Ten Pending Environmental Treaties.  My co-authors and I show the importance of ten treaties and urge the Obama Administration and Congress to work together to ratify them.  Unlike the Kyoto Protocol, these treaties do not generally raise difficult partisan issues.  They were all negotiated with substantial U.S. input, and they all provide clear benefits to the United States – or they would if only the United States belonged to them. 

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Looking Back at the Ozone Retreat: A Step Back for the Obama Administration on Science Integrity

Soon after assuming office in January 2009, President Obama promised that, in contrast to George W. Bush, science and law would be the two primary guiding stars for regulatory decision-making during his administration. From that perspective then, the finalized version of the EPA’s ozone standard should have been a no-brainer. After all, the standard was intended to replace the 2008 one issued in the dying days of the Bush Administration, which EPA Administrator Lisa Jackson has slammed as legally and scientifically indefensible. The Clean Air Act charges the EPA to set the ozone standard at a level that is protective of human health with an adequate margin of safety, and, consistent with this mandate and with the unanimous recommendation of the EPA’s blue ribbon clean air science advisors for how to achieve this mandate, the agency seem poised to set the new standard somewhere between 60 and 70 parts per billion (ppb).

Then politics—in the face of OIRA Administrator Cass Sunstein and White House Chief of Staff Bill Daley—intervened. The Obama Administration turned its back on both science and the law, and ordered Administrator Jackson to stop working on the new ozone standard. Under the circumstances, Obama wasn’t in the greatest position to justify this abrupt about-face.

Not surprisingly, the return letter from Sunstein formally rejecting the ozone rule betrayed more than just a mere soupçon of desperation. Drawing on Executive Order 13563, Sunstein relied in part on two novel considerations—regulatory uncertainty and the current economic situation—to justify the retreat. Then, without a hint of irony, Sunstein went on to claim that the decision was compelled in part by considerations of scientific integrity:

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Robert Adler Op-ed in Salt Lake Tribune Points to Utahn's Desires for Clean Environment and Healthy Economy

Member Scholar Robert Adler had an op-ed in the Salt Lake Tribune over the weekend noting a new survey in Utah showing state residents valuing both a sound economy and a healthy environment as fundamental, co-equal requirements of their quality of life. The survey was part of a "Quality of Life Index" from the Utah Foundation, a group supported by many top businesses in the state.

Adler explained the bigger picture:

Fortunately, clean air and water are not incompatible with jobs and a healthy economy. In the four decades in which the Clean Air Act has been implemented, air pollution in the United States has been reduced by 63 percent while the economy has grown by 210 percent and the nation has created 60 million jobs. Many business people in Utah understand that bad air and dirty water are bad for both quality of life and for business.

Read the full op-ed here.

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Platinum Industry Tries a DQA Complaint the Bush Administration Wouldn't Even Accept

On Monday, the International Platinum Group Metals Association submitted a Data Quality Act complaint (pdf) to EPA regarding a draft toxicological review of halogenated platinum salts and platinum compounds. This one ought to go straight to the agency’s recycling bin.

IPA, as the trade group calls itself, is complaining that the draft document, released by EPA’s IRIS office in 2009 for peer review and public comment, does not meet the standards of objectivity and utility required under the DQA and its implementing guidelines. In IPA’s view,

EPA’s exclusive reliance on [a] single and inappropriate study, as well as the proposed [reference concentration] derived based on that study, constitutes erroneous information, the dissemination of which -- even in “external review draft” form -- contravenes the [DQA].

I won’t go into the scientific debate here because it’s irrelevant to how EPA should handle the DQA complaint. 

Under both OMB’s government-wide and EPA’s agency-specific (pdf) guidelines for handling DQA complaints, the trade association’s complaint is “frivolous” and the agency is well within its rights to decline to review it. The guidelines state that EPA need not review DQA complaints “for which a response would be duplicative.” Since the document that IPA is complaining about is a draft put out by the agency for public review and comment, responding through the DQA process would certainly be duplicative of the upcoming response from IRIS program staff. IRISTrack, the public list of the IRIS program’s schedule for completing ongoing work, shows that agency staff are addressing reviewers’ comments on the platinum salts document right now and will have a final version out by the end of September.

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Draft Scientific Integrity Policies Due from Agencies; Progress Unclear

Today marks 90 days since the last milestone in the White House’s push toward improvements in federal agencies’ scientific integrity policies. Agencies that have made progress in this time ought to release their draft plans and open them to public comment.

 From an outsider’s perspective, there hasn’t been much progress to evaluate recently. It’s something we’ve gotten used to—after an initial push, this administration has not presented much of a sense of urgency in its efforts to set up new scientific integrity policies. 

A quick timeline: President Obama issued an Executive Order in March 2009 that proclaimed the importance of ensuring scientific integrity in the federal government and assigned the task of developing new administration policies to the Director of the Office of Science and Technology Policy (OSTP), Dr. John Holdren. In December 2010, Holdren issued a memorandum to the heads of federal agencies, providing them with guidance and minimum standards for the new scientific integrity policies and giving them 120 days to report to him on their progress. According to a May 5, 2011 blog post by OSTP Student Volunteer Mira Atanassova,

more than 30 executive branch departments, agencies, and offices submitted progress reports on the development of their respective scientific integrity policies. A handful went even further than required and provided draft or complete policies for review.

At that time, Holdren gave all agencies 90 days to submit draft policies.

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Holding its Legal (and Parental) Ground: EPA Responds to the American Chemistry Council's Request for Correction of the BPA Action Plan

Being a parent is not easy, but some of the most difficult moments arise when you know what needs to be done to protect your child and your child has other sentiments. Call it a temper tantrum, a battle of wills, or disobedience, it all evokes a sense of frustration, exhaustion, and, let’s face it, self-doubt. There is that brief moment when you think to yourself, “Wouldn’t it just be easier to let them have their way? Maybe I am being too harsh or paranoid? Is it really going to hurt them?” Unfortunately, for the EPA, these questions and many more weave their way into the complex and detailed decisions that the agency must make on a daily basis in its quasi-parental role. At its core, EPA exists to protect us from dangerous toxins, pollution, and multitudes of health hazards that plague our environment. The “children” with whom EPA deals on a daily basis range in form from individuals to corporations depending on the issue; however, recent events concerning Bisphenol A (BPA), a high production volume chemical used in manufacturing polycarbonate plastics and epoxy resins, starred the American Chemistry Council (ACC) in the role of the strong-willed child.

In March 2010, EPA released its BPA Action Plan, summarizing a variety of scientific findings concerning BPA’s risks and presence in our environment, while also outlining the agency’s intended next steps based on the science. Most of these next steps involved coordinated risk assessment efforts with other government research divisions, such as the National Institute of Environmental Health Sciences, and agencies, like the Food and Drug Administration and the Centers for Disease Control. Additionally, EPA stated that it would “consider” taking steps to place BPA on a Chemicals of Concern List, authorized under section 5(b)(4) of the Toxic Substances Control Act (TSCA) and “consider” initiating an environmental effects test rule under section 4(a) of TSCA. In the grand scheme of EPA’s “parental” authority, the BPA Action Plan was a concerned look and word of caution.

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When Politics Trump Science: How the Ozone Standard's Three-Year Delay Has Already Led to Thousands of Avoidable Deaths

This post was written by CPR President Rena Steinzor and Policy Analyst James Goodwin.

Few incidents better illustrate the Bush Administration’s outright hostility to politically inconvenient science than its 2008 rule updating the ozone National Ambient Air Quality Standard (NAAQS). In the run-up to that rule, Bush’s EPA ignored the unanimous recommendation of the Clean Air Science Advisory Committee (CASAC), an independent and well-respected advisor to the EPA on clean air issues, that it set the standard in the range of 60 to 70 parts per billion (ppb) to replace the existing standard of 84 ppb. Instead, the final rule—issued in the waning days of the Bush Administration—set the standard at 75 ppb, well above CASAC’s recommended range.

The ozone standard was so bad that soon after it was issued in 2008, CASAC took the unusual step of publicly criticizing Bush’s EPA for ignoring its advice.

Fortunately, the Obama Administration, which began before the ozone standard could take effect, delayed its implementation, and in September of 2010, the EPA began a formal reconsideration process to revise the ozone standard. The EPA is now set to issue a final rule setting the ozone standard somewhere in the recommended range of 60 to 70 ppb sometime next month—more than three years late. (In the interim, the original 84-ppb standard has remained in effect.)

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How to Diss A Book Without Reading It

When you write a book, particularly one that has something to do with matters political, you have to expect criticism. So when I wrote Legally Poisoned: How the Law Puts Us at Risk from Toxicants (Harvard, 2011), I fully expected it to take a shot or two – not just from some of my colleagues in academia, but also from allies of the chemical industry.

In fact, since this book isn’t exactly my first rodeo, I’ve grown accustomed to reviewers who sometimes misstate some of the specifics of what I’ve written or mangle an idea or two. But they’re usually mistakes made in good faith, or at least that’s been my impression.

So it came as a surprise to me to read the review of Legally Poisoned written by Henry Miller, M.S., M.D., of the Hoover Institution and adjunct fellow of the Competitive Enterprise Institute. Miller’s got a long history of working to defend potential hazards from regulation, including formerly as a trustee for the corporate funded American Council on Science and Health, so it’s no surprise he didn’t care for my book. What surprised me was that his review suggests that he didn’t bother to read much of it before attacking it.

Legally Poisoned is based on recent research into the developmental origins of disease, and it addresses risks posed to developing children by human-created chemicals. Some of those chemicals have already caused harm; others appear to pose serious risks. But disturbingly, we know very little about the nature of the toxicity for the vast majority, because we have insufficient research on their toxicity and how dangerous they might or might not be.

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