In March 2023, the EPA proposed controversial drinking water regulations for two “forever chemicals,” PFOA and PFOS - setting extremely low allowable levels for both. On May 30, the public comment period ended. How EPA responds to public comments could significantly shape the final rule. This article examines the Administrative Procedures Act (APA) requiring agencies to consider public comment and a few of the significant comments received on the proposed rule.
On February 11, Health Canada proposed guidelines for PFAS in drinking water that are 50,000 – 300,000 times higher than our EPA’s Health Advisories. This article will look at this and another significant issue, the EPA’s classification of PFAS as hazardous substances.
“Products that can’t be made safe can be banned,” said Commissioner Richard Trumka Jr. Are these words just a moment when Commissioner Trumka “got out in front of his skis?” Or, as others have depicted this, a moment when the mask slipped, and the real agenda was transiently exposed?
World War II ended with the bombings of Hiroshima and Nagasaki. Those bombings and the late effects of radiation on the development of cancers in those “survivors” spurred scientific inquiry into the mechanisms underlying human carcinogenesis – the development of cancer. Today’s regulatory science of chemical carcinogens is based upon assumptions and beliefs that are now 75 years old. Our understanding of carcinogenesis has evolved; should our regulatory models shift?
PFAS, the “forever chemicals,” provides a perfect example of how faulty risk assessment can lead to real-world consequences that destroy people’s lives. This happens when federal agencies do not consider relative risk in their analyses and are blinded to the real-world implications of their actions.
Over the past few months more healthcare articles have featured a new (at least for me) statistical methodology: mediation analysis. It doesn’t prove causality, but it can assign a value to the impact of a variable on an outcome. More usefully, it can help suggest what factors we can leverage using public health measures, regulation, or legislation.
The Mercury and Air Toxics Standards (MATS) rule has been a policy and regulatory ping-pong match for over 20 years. Obscured in the regulatory back and forth is a tremendous environmental success story. Yet the regulatory ping-pong match continues. The latest round is that the current Administration’s EPA reaffirmed an Obama Administration legal finding that regulating power plants for mercury is appropriate and necessary.
What is it about science that has allowed our knowledge to advance so rapidly? And why wasn’t science invented long before that pivotal figure, Issac Newton? These are some of the questions that Michael Strevens, a professor of the philosophy of science, attempts to answer in a book called The Knowledge Machine.