Photo: US Air Force

EPA Chemical Office Nominee Alexandra Dunn Must Prioritize Science and Public Health

, Research Director, Center for Science and Democracy | November 27, 2018, 11:38 am EST
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Behind the headlines of the Trump administration’s attacks on science is a quiet army of government scientists continuing to do their jobs protecting the nation’s public health, safety, and the environment. This week, we have the opportunity to ensure a new EPA leader can carry out that mission. On Thursday, the Senate is holding a hearing on the nomination of Alexandra Dunn as Assistant Administrator to run the Office of Chemical Safety and Pollution Prevention, the EPA office charged with protecting us from toxic chemicals and pesticides. Here’s what Senators should demand and expect her to prioritize at the EPA:

At the most basic level, Alexandra Dunn should prioritize protecting the public from harmful chemicals. The EPA oversees chemicals used at homes, in workplaces and the environment and helps ensure people can avoid hazardous exposures. This is a matter of life and death for many and a job that she should take seriously. For example, the EPA has so far failed to ban methylene chloride, a chemical in paint thinners that is responsible for more than 50 accidental exposure deaths. This is the kind of issue that EPA should be addressing immediately and Ms. Dunn can make a difference here.

Alexandra Dunn should resist pressures to bend to industry wishes. Ms. Dunn should resist the ever-present pressure from the chemical industry to weaken and delay chemical regulation of all kinds. The chemical industry lobby, the American Chemistry Council (ACC), has a long history of these efforts. For example, the group spent more than $11 million annually lobbying Congress while the Toxic Substances Control Act was under debate. The ACC has questioned the science around chemicals shown to cause harm and pressured the EPA to alter its science and delay public protections. Such pressures are amplified under the Trump Administration where we know officials are willing to lend an ear to industry voices.

Alexandra Dunn should stand up to colleagues who wish to compromise the science. Specifically, Ms. Dunn should stand up for science against her potential colleague  Dr. Nancy Beck, the deputy assistant administrator in the chemical safety office, who came directly from working as the ACC’s director of regulatory science policy. For more than a decade, Dr. Beck has been fighting to question the rigorous EPA science that backs its chemical policies and delay implementation of life saving protections. When she worked in the White House under President George W. Bush, she helped the Department of Defense slow down EPA efforts to protect drinking water from perchlorate, an ingredient in rocket fuel. At the EPA now, Dr Beck has worked internally to narrowly interpret chemical policies in ways that minimize public protections, which brings me to my final point…

Alexandra Dunn should implement the Frank R Lautenberg Chemical Safety for the 21st Century Act consistent with what Congress intended and prioritizing public protection. Enacted in 1976, the Toxic Substances Control Act (TSCA) charges EPA with overseeing some 84,000 chemicals in consumer products. The law was overhauled in 2016 in response to its overwhelming ineffectiveness. (It successfully regulated just nine chemicals—far under 1%!) The reasons for this ineffectiveness were many and the bipartisan 2016 update was designed to address some of these problems. Ms. Dunn should work to ensure EPA is implementing the law as intended—to protect people from toxic chemicals and do so at a faster pace than the previous law enabled.

Unfortunately, Dr. Beck and colleagues have already wreaked havoc at EPA in TSCA implementation. Several interpretations of the revamped law serve to weaken its effectiveness. In one example, EPA guidelines look to exclude certain scientific studies from agency scientific assessments. Studies where all methods and data aren’t public along with the (mostly academic) studies that don’t employ a standard known as Good Laboratory Practices common in industry studies would be excluded from EPA assessments. Such needless exclusions on what scientific studies can be considered by the EPA are likely to restrict the agency’s use of the best available science and to result in favoring of industry studies over those by independent scientists.

In another example, the EPA is now employing a narrow interpretation of the law, considering only exposures involving a product’s intended use. This means the EPA wouldn’t worry, for example, about exposures to harmful chemicals through the air or water resulting from the disposal of a product. Such an interpretation doesn’t make a lot of sense when we look at the reality of how people are exposed to harmful chemicals. I have two kids under three. I can assure you they will put it in their mouth if they find it. Anything. This kind of exposure—children being exposed to chemicals by putting products in their mouth—wouldn’t be the intended use of many products, but it is reality. It is easy to see how excluding exposures outside of a product’s intended use overlooks many harmful exposures that the EPA should be thinking about how to prevent. Ms Dunn should work to change this and ensure that TSCA is as strong as its sponsors intended.

Additionally, here’s a list of other priorities that Ms Dunn should take on if she is confirmed:

The EPA Office of Chemical Safety and Pollution Prevention has an important job. I hope Alexandra Dunn is up to the task.

Photo: US Air Force

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