EPA’s Integrated Risk Information System does more harm than good

OPINION:

Saturday (April 22) was Vladimir Lenin’s birthday, which some still insist on identifying as Earth Day (isn’t every day Earth Day, really?). As another Earth Day passed, it’s worth thinking about whether and the extent to which the actions of those who regulate in the name of the planet may sometimes be doing more harm than good.

Here’s an example. The Environmental Protection Agency created the Integrated Risk Information System, or IRIS, program in 1985 to identify human health hazards associated with substances. Sounds harmless enough, right?

Unfortunately, IRIS — which has never been authorized by Congress — routinely produces assessments that are either discordant with those of other international bodies, with common sense, or both. 

For instance, the draft IRIS assessment for formaldehyde proposed an acceptable air concentration that is thousands of times below levels that naturally occur in the environment. Formaldehyde is a naturally occurring chemical made of carbon, hydrogen and oxygen. People produce about 1.5 ounces of formaldehyde a day as a normal part of our metabolism, and we inhale it, converted it to carbon dioxide, and exhale it.

Low levels of formaldehyde also occur naturally in a variety of fruits and vegetables, including apples, carrots and bananas. Formaldehyde also occurs as a byproduct from all combustion processes, such as forest fires, automotive exhaust and cooking. In fact, EPA data shows that vegetation and wildfires emit thousands of times as much formaldehyde as the chemical industry.

Formaldehyde helps people create clothes, plywood and carpet, and very little formaldehyde remains in these finished products. It is used to make components of electric vehicles as well as to treat animal feed on farms to prevent outbreaks of African swine fever and salmonella.

So, of course, the EPA — using the assessment from IRIS — wants to make it much more expensive to use and … wait for it … would like to ban it.

If you are a numbers person, the EPA wants to set a limit for formaldehyde at 7 parts per billion. For purposes of context, an apple contains about 6,300 parts per billion of formaldehyde. Every other regulator on Earth has established limits in the hundreds of parts per billion.

Or consider ethylene oxide. It is used by hospitals to sterilize medical equipment. Literally hundreds of thousands of medical, hospital, and laboratory processes rely on ethylene oxide to sterilize devices and protect millions of patients from infectious diseases caused by bacteria, viruses and fungi.

Those who make and use medical devices (like doctors) have argued that ethylene oxide sterilization is the most effective and efficient — and often the only — way to sterilize medical instruments. Apparently, it allows the sterilization of many critical medical technologies and devices that would otherwise be destroyed and rendered unusable by other sterilization methods.

It is also used to make plastics, household cleaners, safety glass, adhesives, textiles and detergents.

That all sounds pretty important. So, of course, our friends at IRIS want to set an acceptable level for ethylene oxide that is 19,000 times lower than the normal, naturally created levels of ethylene oxide that are typically present in the human body and orders of magnitude lower than levels from other sources measured in ambient air.

Again, if you like numbers, IRIS thinks that any exposure to ethylene oxide above 1 part per 10 trillion is unsafe. For contextual purposes, the atmosphere in New Hampshire is about 1,500 parts of ethylene oxide per 10 trillion parts.

There are other examples, but you get the point.

You will probably not be surprised to learn that the EPA and other federal agencies are taking the indefensible numbers from IRIS (which are completely unmoored from reality) and using them to drive regulatory action.

The truth is that, in many instances, regulatory agencies are more about expanding the reach of the federal government than they are about protecting the public. That is not a novel or particularly controversial notion, but it bears repeating, especially as we suffered through yet another round of Earth Day propaganda.

One final thought also bears notice. In announcing planned reductions in the use of ethylene oxide, the EPA’s press release offered that the proposal “advances President Biden’s commitment to ending cancer as we know it.”  

Think for a moment about the lack of humility that underpins that sort of sentiment. Somehow, the Biden administration is going to once and for all, finally and forever, destroy cancer.

The same lack of humility is the foundation for operations like IRIS, who are always ready to assume they know best, irrespective of the evidence.