Corrective Lenses for IRIS: Additional Reforms to Improve EPA's Integrated Risk Information System

Posted: 14 Nov 2010

See all articles by Rena I. Steinzor

Rena I. Steinzor

University of Maryland Francis King Carey School of Law; Center for Progressive Reform

Wendy E. Wagner

University of Texas at Austin – School of Law

Lena Pons

Center for Progressive Reform - CPR Policy Analyst

Matthew Shudtz

Center for Progressive Reform

Date Written: 2010

Abstract

The Environmental Protection Agency’s (EPA) Integrated Risk Information System (IRIS) is the most important toxicological database in the world. Not only is it the single most comprehensive database of human health information about toxic substances, it also serves as a gateway to regulation, as well as to a range of public and private sector efforts to protect against toxic substances. IRIS “profiles” of individual substances include a number of scientific assessments of the substance’s toxicity to humans by various means of exposure – by inhalation, contact with the skin, and so on. Federal regulators rely on the assessments to do their important work protecting the public, as do state and local environmental protection authorities, and industry itself.

Unfortunately, IRIS is woefully incomplete. EPA is many years behind in meeting statutory mandates for completing profiles of at least 255 chemicals, and as a result regulatory and enforcement action related to those chemicals has been stalled. Some chemical profiles in IRIS are missing information essential to regulatory action. In addition, 77 of the hazardous air pollutants (HAPs) listed in IRIS are missing the most important piece of information – an assessment of how much of the substance may be safely inhaled. In all, some 109 chemical profiles that EPA was required by the Clean Air Act Amendments of 1990 to have completed by 2008 are either included in IRIS but missing critical elements, or entirely absent from the database. So severe is the delay in the IRIS process that a 2008 Government Accountability Office (GAO) report warned that the Bush Administration’s approach to IRIS, which resulted in just two completed profiles per year, left the database at risk of becoming obsolete.

To close data gaps and reestablish IRIS’s credibility as a cutting-edge database, EPA needs to make four changes. First, EPA should reduce the procedural burdens that were formalized during the Bush administration. Second, EPA must articulate clear, statute-driven priorities about which assessments to complete to ensure that data gaps in statutory mandates would be more quickly addressed. Third, the IRIS process must be restructured to allow for timely assessments made based on the weight-of-the-evidence at the time an assessment is undertaken. Fourth, EPA must also have adequate resources and make better use of its resources to complete a much larger number of assessments than it is currently finishing each year.

Keywords: toxicology, toxicological database, Environmental Protection Agency

Suggested Citation

Steinzor, Rena I. and Wagner, Wendy E. and Pons, Lena and Shudtz, Matthew, Corrective Lenses for IRIS: Additional Reforms to Improve EPA's Integrated Risk Information System (2010). U of Maryland Legal Studies Research Paper No. 2010-57. Available at SSRN: https://ssrn.com/abstract=1706910

Rena I. Steinzor (Contact Author)

University of Maryland Francis King Carey School of Law ( email )

500 West Baltimore Street
Baltimore, MD 21201-1786
United States

Center for Progressive Reform ( email )

500 West Baltimore Street
Baltimore, MD 21201
United States

Wendy E. Wagner

University of Texas at Austin – School of Law ( email )

727 East Dean Keeton Street
Austin, TX 78705
United States

Lena Pons

Center for Progressive Reform - CPR Policy Analyst ( email )

1200 New York Ave., NW
Suite 400
Washington, DC 20005
United States
202-747-0698 (Phone)

Matthew Shudtz

Center for Progressive Reform ( email )

Washington, DC 20005
United States

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