GAO evaluates EPA biomonitoring strategy
The U.S. Government Accountability Office (GAO) issued areport entitled Biomonitoring: EPA Needs to Coordinate Its Research Strategy and Clarify Its Authority to Obtain Biomonitoring Data that highlights shortcomings in the U.S. Environmental Protection Agency’s (EPA) collection and use of biomonitoring data. This memorandum summarizes the report.
Scope of the GAO Review
In the report, GAO reviews: (1) the extent to which EPA incorporates human biomonitoring data into its assessments of risks of commercial chemicals; (2) steps that EPA has taken to improve the usefulness of biomonitoring data for risk assessment; and (3) the extent to which EPA has the authority under the Toxic Substances Control Act (TSCA) to require chemical companies to develop and submit biomonitoring data. The report analyzes each topic and recommends how EPA could rectify the deficiencies in its biomonitoring strategy. The report is available on the Internet at http://www.gao.gov/new.items/d09353.pdf.
EPA Need for a Strategic Plan
According to GAO, EPA does not effectively incorporate biomonitoring data into its risk assessments. The report cites two reasons for this: (1) nationwide biomonitoring data exist “for only 148 of the over 6,000 chemicals EPA considers the most likely sources of human or environmental exposure”; and (2) most of the available biomonitoring data confirm only that a person was exposed to a chemical exposure, and do not provide information concerning the source of the exposure or its effects. GAO concludes that EPA has not taken advantage of “the recent increase in biomonitoring data” available that could have assisted EPA in its risk assessment.
GAO found that EPA has not created a comprehensive research strategy that would incorporate its own research, as well as that conducted by federal agencies and other organizations. The report notes the “several important biomonitoring research efforts” that EPA now has in place, but criticizes EPA’s lack of a systematic coordinated research strategy. GAO states that there should be some kind of system or plan in place so that EPA can coordinate its research, and research of other agencies and organizations.
As part of its review, GAO concluded that EPA has not determined the extent of the authority it has to require chemical companies to compile and submit biomonitoring data. According to Table 1 in the report, TSCA Sections 4, 5, and 8 address the development and reporting of data. The report states that EPA currently holds no formal position on which, if any, of these sections cover biomonitoring data.
Recommendations
GAO offered the following recommendations, available at http://www.gao.gov/products/GAO-09-353#recommendations:
Recommendation: To ensure that EPA effectively obtains the information needed to integrate biomonitoring into its chemical risk assessment and management programs, coordinates with other federal agencies, and leverages available resources for the creation and interpretation of biomonitoring research, the EPA Administrator should develop a comprehensive biomonitoring research strategy that includes the data EPA needs to incorporate biomonitoring information into chemical risk assessment and management activities, identifies federal partners and efforts that may address these needs, and quantifies the time frames and resources needed to implement the strategy. Such a strategy should (1) identify and prioritize the chemicals for which biomonitoring data or research is needed, (2) categorize existing biomonitoring data, (3) identify limitations in existing data approaches, (4) identify and prioritize data gaps, and (5) estimate the time and resources needed to implement this strategy.
Recommendation: To ensure that EPA effectively obtains the information needed to integrate biomonitoring into its chemical risk assessment and management programs, coordinates with other federal agencies, and leverages available resources for the creation and interpretation of biomonitoring research, the EPA Administrator should assess EPA’s authority to establish an interagency task force that would coordinate federal biomonitoring research efforts across agencies and leverage available resources, and establish such a task force if it determines that it has the authority. If EPA determines that further authority is necessary, it should request that the Executive Office of the President establish an interagency task force (or other mechanism as deemed appropriate) to coordinate such efforts.
Recommendation: To ensure that EPA has sufficient information to assess chemical risks, the EPA Administrator should determine the extent of EPA's legal authority to require companies to develop and submit biomonitoring data under TSCA. EPA should request additional authority from the Congress if it determines that such authority is necessary. If EPA determines that no further authority is necessary, it should develop formal written policies explaining the circumstances under which companies are required to submit biomonitoring data.
GAO states that “EPA agreed with the first two recommendations and did not disagree with the third, but provided substantive comments on its implementation.”
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