Mr. Stephen L. Johnson
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460 Dear Administrator Johnson: We are writing to express our concerns about reports that EPA is considering changes to the chemical risk assessment process that could undermine the credibility of the Agency’s scientific decisions on issues ranging from chemical safety to Superfund cleanup levels. Specifically, EPA reportedly is contemplating adding three additional steps to the chemical risk assessment process, namely two opportunities for “interagency review” and a “technical correction” step, as outlined on the attached diagram entitled “Proposed IRIS Process.” We are concerned that these changes could delay the Agency’s progress in determining chemical risk assessments. Furthermore, by inviting special interest lobbying on chemical risk assessments, these steps would risk politicizing the Agency’s scientific determinations and could undermine the integrity and credibility of the Agency’s technical judgments. According to recent reports, the proposed changes to the Agency’s chemical risk assessment process were proposed in response to pressure from the Departments of Defense and Energy. If correct, this heightens our concern that that these changes would create potential conflict of interests that could compromise the Agency’s ability to protect the environment and public health. The recent controversy surrounding White House alternations to reports on global climate change illustrates the risk of politicizing EPA’s scientific conclusions. We also are concerned that the proposed changes to the chemical risk assessment process will further erode public confidence in our government’s environmental protection policies. Before these new steps are incorporated into the Agency’s chemical risk assessment procedures, we ask that you provide us with a copy of the proposed additions to the chemical risk assessment procedures and that you answer the following questions: 1. What are the purposes of the proposed changes?
2. Will any changes to the chemical risk assessment process be made through notice and comment rulemaking?
3. What safeguards are under consideration to prevent the politicization of the chemical risk assessment process by regulated entities?
4. How will the EPA ensure that the addition of these steps will not cause delays in establishing chemical risk assessments standards and rules?
5. What role has DOD, DOE, OMB, and industry had in developing this new policy? Please provide us with all comments or other written materials relating to the development of the proposed policy? We look forward to your response. Sincerely, U.S. Senators Jim Jeffords (I- VT), Barbara Boxer (D-CA), Frank Lautenberg (D-NJ)