NRDC issue paper: Better risk assessment to better protect health
Today NRDC and the Science and Environmental Health Network (SEHN) together released an issue paper that identifies four key areas where the risk assessment of toxic chemicals could be meaningfully and relatively easily improved. The paper is titled, "Strengthening Toxic Chemical Risk Assessments to Protect Human Health", and can be found here on the website, and as a pdf here. My colleague, Dr. Gina Solomon, is blogging about our paper here.
The issue paper was written and peer reviewed by medical doctors and environmental health scientists that have decades of experience studying the impacts of toxic chemicals on our health. But, don't just take our word for it. The issue paper also relies on key recommendations from several reports of the National Academies, including the groundbreaking Science and Decisions report on Advancing Risk Assessment (2009).
Don't like reading hundreds of pages of National Academies reports? Then, you'll love our issue paper, which takes only ten pages to lay out the key issues for state and federal regulators, risk assessment experts, health scientists, and policy wonks like us.
Here's our recommendations:
1. People are highly variable, and some are more vulnerable to harm from toxic chemicals than others. So, identify this and build it into risk assessments early so all people are protected, even the elderly, young children, and people with illnesses or medical conditions. For example, people with asthma are more vulnerable to dusts and air pollutants, and must be protected.
2. When information is absent, risk assessors must rely on science-based assumptions rather than pretending that no data means no problem. For example, if there is no data about whether a chemical may cross the placenta and enter the fetal circulation, we must presume that it does, so that regulations will provide protection.
3. Consider how exposure to multiple chemicals may impact the overall risk. For example, when assessing the health impact from vehicle exhaust, consider that people are exposed to all the chemicals in the exhaust, and other common air pollutants at the same time. Regulations should not just set a safety limit for each chemical as if it were the only one we breathe.
4. Assume that even low levels of exposure come with risks, unless we have good evidence otherwise. Our scientific understanding of human disease and environmental contaminants is always increasing. We must regulate toxic chemicals so as to protect people in the meantime. For example, we used to think that smoking was only harmful to smokers, but now we know that even second-hand smoke can be terribly damaging to the health of non-smoking family members too. How many lung cancers or heart attacks may have been prevented if we'd take precautions sooner to protect non-smokers from "low doses"?
We need our government agencies to assess the risk of toxic chemicals according to the National Academies recommendations we have laid out here. Thus far, the key federal agencies that assess and regulate chemicals – particularly the EPA and the FDA - -have done too little to implement these recommendations from the National Academies.
Meanwhile, the chemical industry and its Congressional allies, which have had a recent spate of National Academies fever – seeking to mandate EPA follow every NAS recommendation from specific reports – have been silent or hostile to these important, far-reaching, and health-protective recommendations of the National Academies (see more on this here from my colleague Daniel Rosenberg). But cherry-picking their favorites amongst the NAS recommendations does not constitute “sound science.” The EPA, FDA, and other federal agencies should begin implementing these important recommendations, and our political leaders should be supporting those efforts, not simply ordering the science they prefer off the menu provided by the chemical industry.