A National Academy of Sciences (NAS) study committee charged with reviewing advances made to the EPA’s National Center for Environment Assessment and its Integrated Risk Information System (IRIS) program met at the NAS headquarters in DC this week. Over a day and a half, IRIS presented the full slate of activities that the program has been engaging in to modernize and improve the ways that the program is completing its hazard assessment and dose response evaluations.
IRIS assessments on environmental contaminants represent the gold standard for chemical toxicity reviews at the federal, state, and local level, and even internationally. These reviews provide a science basis for many of the standards set by U.S. environmental statues, including the Clean Air Act, Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) also known as Superfund, Clean Water Act, Resource Conservation and Recovery Act (RCRA), The Toxic Substances Control Act (TSCA), and the Safe Water Drinking Act. IRIS is crucial in helping the agency meet its mission to protect human health and the environment. However, because of this program’s critical role in standard setting for federal and state policy, it is often targeted by industry for criticism and even calls to alter its mission or strike the program altogether.
During Thursday’s meeting, IRIS staff expressed concerns about the ability for IRIS to do the work at timelines expected due to staff attrition (now down to just 30 staffers) and lack of funding for external contractors to help with its workload, all while trying to meet Administrator Pruitt’s priority for increased efficiency. Over the course of four information sessions and a poster session, IRIS staff systematically addressed the ways in which the program has made targeted improvements to its processes as NAS recommended in its last review of the program in 2014. Layers upon layers of internal and external peer review and public engagement have been built into the review process using new tools and state-of-the-art methods.
The NAS meeting offered opportunities for public comment at several points throughout the meeting, and there were a series of comments communicating the value that this program offers, from a nonprofit organization that relies on IRIS assessments as it works to remediate superfund sites in New Jersey, to the plight of La Place, Louisiana community members living near a facility emitting chloroprene, a likely carcinogen as determined by IRIS. We cannot afford to have the work of this program diminished or politicized in any way.
My comment in support of the independence and integrity of the IRIS office is below.
Good afternoon, I would like to thank this National Academies study committee for the opportunity to provide this comment today. My name is Genna Reed. I am the science and policy analyst at the Center for Science and Democracy at the Union of Concerned Scientists. The Center for Science and Democracy at UCS advocates for improved transparency and integrity in our democratic institutions, especially those making science-based public policy decisions.
The EPA IRIS program provides a critical scientific service to the public, offering a public searchable database with scientific analyses that inform the decisions that protect us from environmental contaminants. This office is not just important for federal policymaking, but IRIS assessments and associated toxicity values are used by state environmental and public health agencies, as well as community groups, to assess local risks from facilities producing chemicals across the country. This incredibly valuable program must be preserved and protected to conduct its scientific work without political interference. The EPA’s authority to determine the risks posed by hazardous chemicals should not be compromised by interference from other federal agencies or industry stakeholders with vested interests in decision outcomes.
This office has been targeted for political interference in the past. A 2009 U.S. Government Accountability Office (GAO) report found several examples of interference from EPA political appointees, the Office of Management and Budget (OMB), or other agencies to delay or weaken IRIS assessments, including decade-long review processes for naphthalene, formaldehyde, and RDX. A fall 2017 hearing held by the House Committee on Science, Space, and Technology about the integrity of IRIS failed to invite any IRIS staff to talk about the progress of the office. This year, there have even been attempts to defund the program through the appropriations process. Time and time again, the chemical industry has targeted IRIS because new assessments may lead to more stringent standards set based on the best available science on a chemical. Now there is the potential for the IRIS program to move under the jurisdiction of the TSCA program, which would limit the ability of the office to develop risk assessments for a range of industrial chemicals, instead forcing focus solely on those under TSCA’s authority.
IRIS assessments and their staff provide institutional knowledge and assistance not only to risk assessors within the EPA and its regional offices, but also to public health practitioners in state and local governments. It is critical that the career staff scientists that comprise the IRIS office are supported so that they can continue to be a resource for individuals making regulatory decisions about these chemicals. This will allow for federal, state, and local decisions to be based on the best available science, using best methods for systematically evaluating that science. IRIS must continue to be housed in the Office of Research and Development as opposed to the policy office at the Office of Chemical Safety and Pollution Prevention because IRIS represents a scientific database that should be prepared by scientific experts. There is not room for political considerations in the work that IRIS staff do. The EPA’s scientific integrity policy explicitly protects the agency’s scientists and their work from political interference or personal motivations, thus NAS should consider what a potential restructuring of the program would mean for its ability to conduct scientific work free from interference.
NAS has acknowledged some of IRIS’ challenges in the past, including room for improvement in transparency in communicating risks and decision points to the public and standardizing assessments, updating methodologies, and regularly training employees. Its most recent report in 2014 found that IRIS had made impressive strides toward implementing their previous recommendations. The EPA Science Advisory Board found similar results after reviewing IRIS progress. In a September 2017 letter from the chair of the EPA’s Science Advisory Board (SAB), the Board commended the agency for its swift improvements to the IRIS program.
At a time when the agency’s staff is shrinking and science advisors are being underutilized, the EPA needs its robust scientific staff to continue the work that has sustained stringent standards at the federal level and beyond. The healthy functioning of the IRIS program will ensure that we continue to have the data to set health-protective limits for hazardous chemicals and ensure public trust that the EPA has our best interests in mind.
 Integrated Risk Information System (IRIS). Online at https://cfpub.epa.gov/ncea/iris_drafts/simple_list.cfm, accessed January 30, 2018.
 United States Government Accountability Office. Low Productivity and New Interagency Review Process Limit the Usefulness and Credibility of EPA’s Integrated Risk Information System. Report to the Chairman, Committee on Environment and Public Works, U.S. Senate. Report No. GAO-08-440; March 2008. Online at http://www.gao.gov/new.items/d08440.pdf, accessed January 30, 2018.
 United States House of Representatives Committee on Science, Space, and Technology, Joint Subcommittee on Environment and Subcommittee on Oversight. 2017. Examining the Scientific and Operational Integrity of EPA’s IRIS Program, Hearing, September 7. Online at https://science.house.gov/legislation/hearings/joint-subcommittee-environment-and-subcommittee-oversight-hearing-examining, accessed January 30, 2018.
 Erickson, B.E., C. Hogue, J. Morrison. 2017. Trump EPA to shed chemical programs, grants. Chemical and Engineering News. Online at https://cen.acs.org/articles/95/i17/Trump-EPA-shed-chemical-programs.html, accessed January 30, 2018.
 United States Senate Committee on Appropriations. 2017. Summary: FY2018 Interior, Environment Appropriations Chairman’s Mark Released, November 20. Online at www.appropriations.senate.gov/news/minority/summary-fy2018-interior-environment-appropriations-chairmans-mark-released, accessed January 30, 2018.
 U.S. Environmental Protection Agency (EPA). 2014. U.S. Environmental Protection Agency Scientific Integrity Policy. Online at www.epa.gov/sites/production/files/2014-02/documents/scientific_integrity_policy_2012.pdf, accessed January 30, 2018.
 National Research Council. 2014. Review of EPA’s Integrated Risk Information System (IRIS) Process. Washington, DC: The National Academies Press. doi:10.17226/18764.
 Thorne, P.S. 2017. Letter to EPA Administrator E. Scott Pruitt, September 1. Online at https://yosemite.epa.gov/sab/sabproduct.nsf/0/A9A9ACCE42B6AA0E8525818E004CC597/$File/EPA-SAB-17-008.pdf, accessed January 30, 2018.
 Friedman, L., M. Affo, and D. Kravitz. 2017. E.P.A. Officials, Disheartened by Agency’s Direction, Are Leaving in Droves. New York Times, December 22. Online at www.nytimes.com/2017/12/22/climate/epa-buyouts-pruitt.html, accessed January 31, 2018.
 Reed, G., S. Shulman, P. Hansel, and G. Goldman. 2018. Abandoning Science Advice: One Year In, the Trump Administration is Sidelining Science Advisory Committees. Cambridge, MA: Union of Concerned Scientists. Online at www.ucsusa.org/sites/default/files/attach/2018/01/abandoning-science-advice-full-report.pdf, accessed January 31, 2018.
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