Posted on June 8, 2020
Today the Environmental Protection Agency (EPA) Science Advisory Committee on Chemicals (SACC) begins a four-day public meeting focused on the Draft Risk Evaluation on Asbestos that was released on March 30, 2020. The meeting requires registration. ADAO will be participating and submitting both an oral and written statement.
Asbestos is a known carcinogen that continues to kill nearly 40,000 Americans every year. This is irrefutable.EPA Administrator Andrew Wheeler admitted in a recent testimony that EPA would not be addressing legacy asbestos in its risk evaluation. Instead, the organization may issue a separate evaluation for legacy asbestos sometime in the future.
Not only is the draft asbestos risk evaluation ignoring legacy asbestos, but it also ignores many forms of disease, and exposure pathways. As a result, many stakeholders, public health advocates, scientists, doctors, asbestos experts, Attorneys General, and concerned citizens have submitted comments to Administrator Wheeler to demand a change in the Draft Asbestos Risk Evaluation. You can read comments from just a few of them below to learn more about their deep concerns surrounding the draft risk evaluation.
Below you will also find four full statements concerning the flaws and dangers of the draft risk evaluations from ADAO, AGs, APHA, Safer Chemicals, Healthy Families. As leaders in this field, we hope that our voices will be heard and that EPA will carefully review and consider our docket submissions and amend their risk evaluation as a result.
Together, we make change happen.
Linda Reinstein
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Attorneys General from Massachusetts, California, Hawaii, Illinois, Maine, Maryland, Minnesota, New Jersey, New York, Oregon, Rhode Island, Vermont, Washington and the District of Columbia: “We call on EPA to revise its approach to evaluating the risks posed by asbestos to comply with its obligations under TSCA and obtain the information it has admitted it needs to conduct the necessary, thorough evaluations of the risks presented by asbestos before issuing any final asbestos risk evaluation.”
Barry Castleman, ScD: “The EPA draft fails to account for the maximal exposures that arise in the life cycle of some asbestos products. It is important to not only account for the fact that such high exposures can occur but that they continue, notwithstanding government efforts to warn and regulate such exposures.”
Penny Fenner-Crisp, PhD, Environmental Protection Network: “This draft risk evaluation concludes that every condition of use evaluated poses an unreasonable risk to public health, in both the occupational (workers and occupational non-users (ONUs)) and consumer (users and bystanders) setting. It is time to proceed directly to rule making with a proposal to BAN the importation, manufacture, processing, distribution and use of asbestos for all commercial and consumer uses in the U.S. on an expedited timeline. Over 30 years have passed since the 1989 rule failed, during which alternatives could have been developed. There is no excuse for delaying action any further.”
Arthur Frank, MD, PhD: “The scope of the EPA assessment should not be limited to chrysotile alone, since there are legitimate reasons for also considering amphiboles. Workers and the general public are both still regularly exposed to amphiboles.”
Brent Kynoch, Environmental Information Association: “EPA’s decision to make a risk evaluation and ultimately a risk assessment based only on mortality rates relating to asbestos exposure and to not include incidences of cancer severely underestimates the risk associated with asbestos exposure. By not considering legacy exposures as an integral part of the current risk evaluation, it has narrowed the modeling and by EPA’s own admission, has undercounted both exposure and likely the mortality rates.”
Richard Lemen, MSPH, PhD: “In limiting the Draft Risk Evaluation to do a chrysotile-specific risk analysis is not realistic since, by doing so it screened out all studies in which exposures were not solely to chrysotile, ending up with only two studies to calculate the IUR.”
Jacqueline Moline, MD, MSc: “Asbestos in talc is linked to ovarian cancer yet EPA has excluded all asbestos-related malignancies from the evaluation except for lung cancer and mesothelioma. In addition, the asbestos found in talc is a mixture of fiber types but EPA only examines risks from chrysotile in the mistaken belief that this is the only fiber in current products. If asbestos in talc is added to the draft evaluation, EPA would need to address both of these limitations so that talc-related risks could be fully assessed.”
Celeste Monforton, MPH, DrPH, American Public Health Association: “The agency’s draft risk evaluation is incomplete and its assumptions inappropriate. It fails to address, for example, the risk created by the millions of metric tons of asbestos already in use —-This means ignoring the risk to communities where families live in substandard housing and children going to school where cities have disinvested in public buildings. This risk is increasing because of extreme weather events brought on by climate change.”
Patrick Morrison, International Association of Firefighters: “we believe that the EPA should evaluate fire fighters as a susceptible subpopulation, and evaluate legacy exposure in their chemical risk evaluation process. Firefighters face a high risk of asbestos exposure, because asbestos becomes airborne when disturbed or damaged by fire.”
Christine Oliver, MD, MPH, MS, FACPM: “The EPA’s singular focus on mortality vs. incidence underestimates the health risk of asbestos for at least two important reasons. First, incident asbestos-related disease is far more prevalent than asbestos-related mortality in developed countries, particularly with regard to nonmalignant diseases such as asbestosis. Second, the EPA uses outdated survival data for lung cancer and malignant mesothelioma from 1975-2010 to characterize survival from these two cancers as short-term following diagnosis.”
Linda Reinstein: “The facts are irrefutable. Each year, nearly 40,000 Americans die from preventable asbestos-related diseases. Nearly 70 countries have banned asbestos, yet the United States is leading the race to the bottom in its inability to act. . Our government has failed time and time again to ban this known carcinogen. Since 1989, we have consumed nearly 400,000 metric tons of asbestos and buried one million Americans.”
Robert Sussman, JD: “Asbestos is not any chemical but a uniquely hazardous substance that has taken the lives of over a million Americans. There is a compelling need to inform the public about this enormous threat to public health, but the draft EPA evaluation ignores critical aspects of asbestos exposure, disregards known health effects and greatly understates risks.”
Raja Flores, MD: “Mesothelioma is always fatal. I ask everyone who is considering this draft risk evaluation to consider what it is like to slowly watch your loved one lose the ability to breathe, to go through endless surgeries or get a lung removed to elongate their life and time with you by a few months, to fight a disease that has no cure. All because they were exposed to asbestos, a known-carcinogen.”
“I must express my disappointment in the draft risk evaluation because it does not do enough to identify and estimate the risks of all pathways of asbestos exposure that can cause mesothelioma.”
SAFER CHEMICALS, HEALTHY FAMILIES with 27 signatures
“EPA must strengthen the current draft significantly to incorporate comprehensive use and exposure information and the best available science and to remove the many exclusions and limitations that result in an understatement of risk. These necessary improvements would both reinforce EPA’s determinations of unreasonable risk and provide additional support for the complete asbestos ban that EPA must impose under TSCA.
Tom Laubenthal: “EPA is ignoring work practices that is part of daily work with the vast array of Asbestos-Containing Material (ACM) present in an almost incalculable amount across 50 states and Puerto Rico.”