Reflections on Reform

There has been no shortage of news articles and blog posts about the recent passage of the Frank R. Lautenberg Chemical Safety for the 21st Century Act, which amends the ineffective and outdated 1976 Toxic Substances Control Act (TSCA). And, you probably don’t need to read another description of the strengths and weaknesses of the ultimate compromise. (If you do want a quick primer on why this reform matters, though, I would recommend this NPR interview with my former boss, Richard Denison, or his post on why this is a “really big deal.“)

Nevertheless, I want to add some reflections of my own on this historic occasion.

As a student in the environmental health field, this bill is particularly significant to me. Not only does the reform directly influence issues that I think about constantly, both personally and academically, but it will also likely set the stage for my future career.

It is exciting to think that I, along with fellow classmates in toxicology, environmental epidemiology, and exposure science programs across the country, will soon be able to participate directly in the implementation of this updated chemical safety system. We can feel a new sense of possibility with our work, instead of the backdrop of futility that comes when we learn in our foundational courses that – despite the damning evidence- the Environmental Protection Agency (EPA) could not even ban asbestos(!). With that (previous) reality in mind, could there be any hope that our efforts studying other potentially harmful chemicals would ever make an impact? As an analogy, what if there were a law that prevented the Centers for Disease Control and Prevention (CDC) from implementing effective vaccination programs? How would budding infectious disease epidemiologists feel about their opportunities for contributing to real public health advancements? Now, with the Lautenberg Act, we have a new framework in place that will at least offer the chance for us to use our research to make a difference. I hope that this will inspire others to join this dynamic, interdisciplinary field.

TSCA reform will impact and energize many aspects of environmental health. For example, the new mandate for safety reviews of all chemicals in active commerce will require investment in efficient and accurate screening tools. New testing technologies are already being developed, but further work and innovation – as well as input from a diverse array of scientists – will be necessary to ensure their reliability, relevance, and validity.

In addition, this reform will likely spur more research to understand the unique susceptibility of certain populations. The bill contains provisions that explicitly require protection of “potentially exposed or susceptible population[s].” This category includes “infants, children, pregnant women, workers, and the elderly,” but also other individuals who may be “susceptible to greater adverse health consequences from chemical exposures than the general population” – for example, because of their genetics. The study of gene-environment interactions (also known as “toxicogenetics”) aims to investigate specific genes that make some individuals more sensitive to chemicals. Dr. Francis Collins, director of the National Institutes of Health, summed up this idea with the phrase “genetics loads the gun, but the environment pulls the trigger.” Toxicogenetics is already a rapidly growing field, but I anticipate future work in this area will be crucial in helping us to determine the levels at which regulations should be set to ensure protection for those who are most vulnerable.

While there will likely be numerous positive consequences of the reform bill, the success of this updated chemical policy system is far from guaranteed. Numerous roadblocks may appear, such as the possibility of a mismanaged EPA or the paralyzing impact of endless cost-benefit analyses in risk management decisions. Passing TSCA reform was a difficult and momentous task, but the hard work will continue. We must maintain pressure to hold EPA accountable, prevent entanglement by special interests, and ensure the law is executed correctly. And, Congress must provide adequate funding to environmental health research programs, which will produce key scientific evidence to guide EPA and educate the next generation of scientists (like me!).

This compromise was not perfect, but the bill does represent a real improvement over the status quo. Now, the environmental health community has an exciting chance to help make its enactment as strong as it can be, through robust research and continued advocacy.

I can’t wait to play my part.