Update: On March 24, 2022, UCS submitted a public comment to the Environmental Protection Agency (EPA) detailing our support for robust science to protect people from the dangers of ethylene oxide and how we stand firmly against the attempt by industry to manipulate the rulemaking process. Read on for the backstory and how you can add your voice.
Since 2019, a Texas state agency and its industry partners have been actively working to challenge the Environmental Protection Agency’s (EPA) own science on the harms of ethylene oxide, a cancer-causing gas that affects thousands of people across the nation, especially those living in underserved communities. In 2020, the notoriously industry-friendly Texas Commission on Environmental Quality, along with the industry trade association American Chemistry Council and the firm Huntsman Petrochemical, submitted a petition to the EPA claiming that the work of EPA scientists is suspect and pressed the EPA to support the adoption of a far less protective standard based on the Texas Commission’s analysis.
The EPA recently weighed in on that petition. They formally rejected the analysis by the Texas Commission on Environmental Quality and stated that the EPA’s analysis remains the best available science to determine the health risks from ethylene oxide. Furthermore, the agency announced plans to use that EPA science in future rulemaking so as to better protect communities from industrial sources of the dangerous gas.
In other words, the EPA told the industry groups to take their cherry-picked analysis elsewhere, because the agency is not buying it. The response marks an important win for scientific integrity at the agency and something UCS has been calling for.
The EPA’s IRIS assessment represents the best available science
Ethylene oxide is a colorless gas that can cause short-term health effects such as headache, dizziness, nausea, fatigue, respiratory irritation, and long-term health effects such as several types of cancers including non-Hodgkin lymphoma, myeloma, and lymphocytic leukemia, and for cis-gender women, breast cancer. Breast cancer risks may also include people of other gender identities but our knowledge is more limited.
Industrial sources make up one of the major sources of ethylene oxide, specifically facilities that sterilize medical equipment. Communities located at the fenceline of these facilities—disproportionately Black, Latinx, Indigenous, and low-income communities—are at particular risk of exposure to the dangerous gas. According to an analysis by ProPublica, ethylene oxide is the biggest contributor to excess industrial cancer risk from air pollutants nationwide.
In 2016, the EPA released its Integrated Risk Information System (IRIS) assessment for ethylene oxide, taking a deep dive into the potential health effects linked to the chemical gas. IRIS assessments on environmental contaminants represent the gold standard of chemical toxicity reviews at the federal, state, and local level, and even internationally. The 2016 IRIS assessment involved a decade-long process to systematically review and assess toxicological and epidemiological evidence about the health risks of ethylene oxide, which included a robust peer review process involving EPA scientists, independent scientists from the agency’s Science Advisory Board, and the public.
While the scientific community has known for decades that ethylene oxide could damage people’s DNA, a condition that can lead to cancer, the 2016 IRIS assessment brought to light just how dangerous the cancer risk from ethylene oxide actually is. The assessment concludes that people who continuously inhale the chemical as adults face 30 times more cancer cases than the agency had previously thought—50 times more cancer cases for those who are exposed since birth.
Texas agency’s analysis is flawed and biased
By way of comparison, the analysis submitted by the Texas Commission on Environmental Quality used non-transparent methods to cherry-pick the data so as to diminish the health risks associated with ethylene oxide exposure. The analysis was also guided by people with major conflicts of interest. For instance, Michael Honeycutt, the former head of the Commission’s toxicology division in 2019 when the analysis was first developed, previously worked as a petrochemical lobbyist. Additionally, the Texas Commission spent years in court trying to prevent the release of thousands of pages of documents it had relied on as the technical basis for its analysis. My colleague Genna Reed first reported on this alarming situation in January 2020.
Importantly, the Texas Commission’s analysis is not based on new data or new scientific research. Instead, it reanalyzes the ethylene oxide exposure data used by the EPA IRIS program, a National Institute for Occupational Safety and Health dataset of over 19,000 workers. But the Texas analysis adopted a value to estimate the cancer risk that is 2,000-fold less protective than that used by the EPA. According to the EPA, the Texas Commission’s analysis arrived at this number in part by excluding women from their analysis, thereby excluding “all lymphoid cancers in women, as well as the exclusion of breast cancer [in women] as an endpoint.”
We’ve seen this tactic before. During the prior administration, industry groups and their allies sometimes pressured federal scientists to reanalyze data in a biased manner to support a foregone conclusion (see here and here). This tactic is part of the disinformation playbook industry uses to undermine the science policy process and hinder agencies from developing and implementing strong public health and environmental protections. You can see this tactic on full display on the website of the Texas Commission on Environmental Quality, where the “commonly asked questions” section on ethylene oxide is filled with misleading and biased questions meant to downplay the chemical’s health harms, such as the very first question: “Is EtO [ethylene oxide] made naturally in the body?”
Tell the EPA you support science
To date, the EPA does not have a stellar track record when it comes to protecting communities from ethylene oxide. The EPA has previously failed to communicate the findings from its 2016 IRIS assessment to impacted communities, particularly to Black and low-income communities, leaving those residents unaware of the immense health risks they face when breathing in the air in their neighborhoods. Therefore, it is vital that we hold the EPA to account and press the agency to carry out robust and equitable science-based decisionmaking to protect communities from ethylene oxide’s immense health burdens.
If you feel strongly that the EPA needs to use the best available science to safeguard communities from the threat of ethylene oxide, you can add your name to this letter and tell the EPA directly (bonus points for sending a personalized comment using this guide). The EPA’s recent decision to use its own science and to reject the analysis they were pressured to adopt by industry, now stands in the form of a proposed rule. You can add your voice to tell the EPA they need to listen to the findings of their own scientists and use the robust and peer-reviewed 2016 IRIS value to protect the health and safety of communities across the nation from this dangerous chemical.