A rigorous independent review by scientific experts of the National Academies of Sciences (NAS)—the Nation’s premiere scientific institute providing non-partisan objective guidance for policy makers - continues to praise the EPA Integrated Risk Information System (IRIS; See NAS DELS-BEST-17-03). The Academies is joined in its praise by NRDC and 90 scientists, environmental health experts, medical professionals, and community leaders that issued a letter of support for the IRIS Program's independence from toxic chemical manufacturers and polluters. The committee concluded that Overall, it was impressed with the changes being instituted in the IRIS program since its 2014 report, which also praised the program.
The Academies made two important points that were identified in NRDC comments that I presented to the Committee:
- The Academies specifically praised the EPA career staff for their leadership in implementing systematic review methods initiated over the last several years;
- The Academies specifically supported current best practices recommended by the Institute of Medicine that, "the IRIS teams involved in the systematic-review process should be independent of those involved in regulatory decision-making who use the products of the systematic-review teams. The committee notes that the current organizational structure of the IRIS program in the EPA Office of Research and Development is consistent with those best practices." (NAS 2018, p. 8)
In its simplest terms, the above recommendations mean that the IRIS program should stay where it is within the science office at EPA, and continue to be staffed and led by EPA career scientists. It should not be moved to the regulatory programs within EPA. Yes!
It would be extremely problematic if the IRIS Program were moved into the Office of Chemical Safety and Pollution Prevention (OCSPP) which regulates pesticides and toxic chemicals, and which is now run by the regulated industry and polluters. Such a shift is called for in the current Senate FY2018 Appropriations Bill (see Minority Response). This shift would move IRIS from a science and research office to a regulatory policy office under the management of Nancy Beck, a chemical industry lobbyist prior to her recent political appointment at EPA. Dr. Beck’s previous foray into developing risk assessment guidelines was a failure, as evidenced by the NAS conclusion that the draft government-wide risk assessment bulletin which she authored while at the Office of Management and Budget (OMB) was “fundamentally flawed” and the unprecedented recommendation for its withdrawal (NAS 2007).
IRIS is a very valuable public government program, because the IRIS Toxicity Values (how much exposure to a chemical can cause how much cancer or other health harm in a person or community) are used by regulators at the EPA, by local, state and regional governments, and around the world to set health-based limits for chemicals in air, water, food or soil. IRIS assessments are also used by forward-thinking and sustainable chemical and product manufacturers, fabricators, and retailers to build safer and more sustainable products. It has earned praise from previous National Academies reviews (NAS 2014), and more recently praise from EPA’s independent Science Advisory Board (SAB, Sept 2017), whose own independence is also under severe attack, as the Trump EPA replaces independent academic experts with anti-regulatory, climate-denier, and industry appointees.
In short, IRIS is in a fight for its life, as EPA political appointees tighten the noose. The protection of EPA’s scientific independence and integrity is of great concern to state environmental and health departments, manufacturers, businesses, scientists, academics, health professionals, and the public. That’s why NRDC and 90 scientists, environmental health experts, medical professionals, and community leaders have signed a letter of support for the IRIS Program as it is under siege by the chemical manufacturers.
We are very pleased that the 2018 National Academies review provides support for the IRIS program to continue as an independent chemical assessment program committed to using the best scientific methods for ensuring protection for public health and the environment.