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The National Academy of Sciences (NAS) announced in December 2017 that it will again review EPA’s Integrated Risk Information System (IRIS). Previous NAS reports, one in 2011 and another in 2014, found serious problems with IRIS and offered sweeping recommendations to overhaul the program.
NAS is not alone in identifying critical issues that need reform with the IRIS program. Since 2008, the Government Accountability Office (GAO) has regularly highlighted its concerns with regard to IRIS because of fears that the program is at risk of becoming obsolete due to an inability to produce quality chemical assessments in a timely manner. Congress has also repeatedly expressed serious concerns with regard to IRIS and has held numerous hearings in recent years—including one last September—to discuss those ongoing problems.
EPA’s mission is to protect human health and the environment. The agency originally designed the IRIS program to support this mission by using scientifically defensible methods and approaches to identify and characterize health hazards. The program has had repeated problems achieving that goal, though.
In 2016, Congress passed the Lautenberg Chemical Safety Act (LCSA), which requires EPA to use the best available science and a weight of evidence process when evaluating the risk from new and existing chemicals. Consistent application of these core scientific standards is fundamental to achieving EPA’s mission. Given the concerns that have been raised by NAS, GAO, Congress, and many in the scientific community, it is not clear that IRIS assessments qualify as the best available science, applied in a weight of the evidence approach.
Tying their own hands
Initially, it was encouraging to hear that the latest review by NAS will assess changes to IRIS that that EPA has implemented or plans to implement based on recommendations from NAS. Unfortunately, on closer review, it appears the NAS is tying its own hands in its official statement of task for the review:
“The committee primarily will base its assessment on EPA presentations and interactive sessions during a 1.5 day workshop at which multiple opportunities will be provided for stakeholder input.”
The constraints NAS is placing on itself will prevent it from fully evaluating—based on a well-informed, full, and fair scientific assessment—whether:
The committee has further constrained its ability to produce a thorough assessment by only allowing itself nine months to complete the review. Although we encourage its timely completion, NAS should ensure that it takes sufficient time to effectively evaluate the changes made to the IRIS program and to solicit additional stakeholder engagement and input.
Ensuring a robust committee review
To conduct an effective review of the IRIS program, NAS should revise its statement of task to:
Getting it right
The recommendations outlined above will allow NAS to fully consider recent improvements made to the IRIS process and identify the areas that EPA needs to continue working on to improve the program so that it can produce chemical assessments in a way that is transparent to the public, timely, and reflective of the best current scientific methodologies.
Science is essential to understanding the world’s most pressing challenges and to overcoming them.
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