NAPA continues advocacy for valid, toxicological-based PFAS regulations

Over the last two months, NAPA has joined in coalition efforts to impress upon the Environmental Protection Agency (EPA) that more must be done to ensure underlying chemical regulation is based on valid science.

We and others are adamant that EPA overstepped its authority by proposing to add certain PFAS forever chemicals to their Toxics Release Inventory (TRI) reporting program. At issue is that the underlying toxicity of these chemicals simple do not warrant inclusion for TRI reporting, as illustrated in our comments.

Similarly, we joined in a recent effort to ask EPA to review their internal process for developing toxicity values for a variety of chemicals, called the Integrated Risk Information System (IRIS). This system assesses existing chemical toxicity data, placing large downward factors on uncertainties. Those uncertainties are compounded, and in the case of PFAS, for example, results in drinking water standard that are in the parts-per-trillion – even below what can actually be measured. Similarly in the case of well-known chemicals like formaldehyde and chlorinated solvents, EPA’s IRIS factors result in risk-based outcomes that require additional management across ours and other industries. For example, it’s well known that formaldehyde is a top risk-driver for asphalt mix plant permitting. And those risk values are derived from the underlying IRIS database. That is why we are calling to EPA’s attention their internal processes associated with setting IRIS values, as illustrated in our coalition comments.

NAPA continues to advocate with regulatory agencies and Congress, on behalf of the industry, for better accountability and validity in the environmental agency rulemaking process. Our most recent letter to Congress similarly illustrates the impact to our industry, from EPA’s chemical safety rulemaking processes, which have come into question.