Dear Administrator Johnson:
The undersigned environmental and public health groups join together in urging you to withdraw recent changes to the U.S. Environmental Protection Agency’s (EPA) chemical assessment program, the Integrated Risk Information System (IRIS). The new policy issued in April, without opportunity for public notice and comment, will prolong the public’s exposure to unsafe levels of toxic chemicals and hinder the ability of EPA and states to establish health-protective standards for drinking water, air pollution, and cleanup of toxic waste sites. We urge you to reverse these changes to help restore scientific integrity and transparency to EPA decision-making.The EPA established the IRIS program in 1985 to determine the human health risks related to exposures from hundreds of toxic chemicals. IRIS integrates in-house research from EPA scientists, peer review by outside experts, and input and comments from the public. Under recent procedural changes forced on the program by the White House Office of Management and Budget (OMB), however, other federal agencies with significant conflicts of interest such as the Defense Department are now able to weaken and delay the Agency’s own scientific assessments of hazardous chemicals.

For many years, IRIS assessments were developed by EPA scientists. Drafts were released simultaneously for public comment and external (independent expert) peer review. OMB and government agencies such as the Defense or the Energy Department (DOD or DOE), that sometimes had a stake in the outcome of the evaluation because of their obligations to address contamination at federal facilities, had an opportunity to review and comment on the draft when it was released for public review and comment. Comments from these agencies, whether of a scientific nature or policy-based were available for public scrutiny.

The new process established by the White House turns this process on its head: it invites the injection of non-scientific considerations into the IRIS assessments, and further, it shields from public scrutiny the input from other parts of the government with a potential financial or political interest in the outcome of a particular assessment. When political appointees and polluting agencies are able to interfere in a non-transparent and inappropriate manner the whole process is severely compromised. This type of interference has already led to years-long delays in setting health protective standards for widespread environmental contaminants including trichloroethylene (TCE), formaldehyde, and the rocket fuel additive perchlorate.

The new 2008 IRIS process introduces three new opportunities for non-health agencies and OMB to weigh in on EPA’s health assessments, and allows other agencies to impose an 18 month delay for chemicals they deem to be “mission critical.” Importantly, interagency and OMB comments will be shielded from public view, preventing peer-review of scientific arguments or scrutiny of policy arguments that should not be considered in a scientific assessment of health risks posed by chemicals. In addition, the Agency must essentially receive “sign-off” from OMB and other agencies before a health assessment can be finalized.

The U.S. Government Accountability Office (GAO) recently released its review of the new process, in a report entitled: Low Productivity and New Interagency Review Process Limit the Usefulness and Credibility of EPA’s Integrated Risk Information System. This report provides a detailed and highly critical assessment of the failures of the IRIS program to meet its deadlines and requirements, blaming in large part the interference by polluting agencies and political appointees. The GAO report predicts that the new process will produce IRIS assessments that lack credibility, and will worsen what is already a critical backlog of new and updated assessments. Without an open, credible, effective, science-based, fully-funded program to develop these assessments without political interference from the White House or other federal agencies, EPA will continue to fall further behind in a fundamental program that serves as the foundation for fulfilling its mission: protecting the environment and public health. We urge you to withdraw this damaging policy and to work towards restoring integrity to EPA’s program for assessing the threats chemicals pose to public health.

If you or your staff have any questions please contact Jennifer Sass, Natural
Resources Defense Council. Tel: 202-289-6868, Email: jsass@nrdc.org
Respectfully,

Green Group Coalition

Health and Environmental Advocacy Organizations

Read Letter Here