Peer-Review Committee Challenges the EPA’s Draft Risk Evaluation for Asbestos

The document also detailed precautionary measures for asbestos safety.

As part of the EPA’s risk-assessment process, the draft was open for public comment for 60 days and underwent a peer review. Eventually, the agency will compile a final risk assessment.

The EPA created this draft risk evaluation compliant with the Toxic Substances Control Act (TSCA). This law regulates new chemicals or those currently in use in the United States. Asbestos is a substance covered under this law.

The EPA composed the draft based on the following information:

• A review of scientific literature
• Modeling and other risk-assessment activities
• Analysis of current uses of asbestos
• Data around asbestos exposure, toxicity and transport from various sources
• A determination if current conditions of asbestos use pose an “unreasonable risk” to the environment or human health

_{The EPA provides additional information on their research, goals and findings on their website.}

What Were the Findings From the EPA’s Draft Risk Evaluation for Asbestos?

The EPA came to two preliminary determinations about asbestos risk based on “current conditions of use.” The organization based its evaluation on 33 conditions of use. Their main preliminary determinations were:

1. There is no unreasonable risk to the environment based on the conditions of use evaluated.

2. There is unreasonable risk to people. Workers, consumers, occupational non-users and bystanders could be “adversely affected” under certain conditions of asbestos use studied during the evaluation.

The draft risk evaluation and initial risk assessments are preliminary. Findings and conclusions are not final and must undergo review by independent scientific experts.

The document provides additional details about what the organization studied, including asbestos disease type, asbestos type, asbestos exposure type and more.

Concerns About the Draft Risk Evaluation’s Findings

The review committee (SACC) has expressed concerns about the EPA’s draft. The SACC believes the draft underestimates the risk asbestos poses to humans.

SACC concerns about the EPA draft include:

• The occupational exposure findings focus on “present commercial chrysotile asbestos,” not all types of the mineral.
• The draft doesn’t consider “legacy impacts,” such as existing asbestos building materials.
• The draft doesn’t consider contaminated articles or products (such as talcum powder).
• “Take-home” exposures are not addressed.
• The draft could be underestimating the number of health risks resulting from asbestos. For example, the draft only assessed risk and related data for lung cancer and mesothelioma, rather than all asbestos diseases.
• Assumptions about personal protective equipment (PPE) use scenarios are unrealistic.

_{Additional concerns from the SACC review can be found in the TSCA SACC Meeting Minutes and Final Report.}

Calls for Action on the EPA’s Draft

The SACC’s recommendations require revisions to the EPA’s draft risk evaluation. Some of the SACC recommendations include:

• Health risks should account for all types of asbestos, not just chrysotile.
• Mortality data should address all asbestos cancers and non-cancerous asbestos disease.
• Data should reflect incidence, not just mortality.
• Risk factors/estimates associated with PPE use scenarios should not be taken into account in the risk characterization.
• Labeling and organization of the draft should be more specific. For example, the title should be specific to chrysotile asbestos, and data regarding other types of asbestos should be clearly labeled.
• The draft should include levels of confidence for each TSCA risk determination. Some risk estimates are “based on little to no data.”

_{Additional recommendations from the SACC review can be found in the TSCA SACC Meeting Minutes and Final Report.}

Other organizations, such as the Asbestos Disease Awareness Organization (ADAO), have expressed similar concerns about the draft.

Critics hope the EPA will take action to correct the limitations identified in the draft. Through this risk evaluation, the EPA is in a position to advise and implement asbestos regulations that can protect individuals from diseases, such as mesothelioma cancer.

Advocates for asbestos safety assert the importance of asbestos regulations. There is still no complete ban on asbestos in the United States.

The EPA is currently reviewing the SACC’s feedback. A final risk evaluation is forthcoming.