On September 7, 2022, the Environmental Defense Fund (EDF) held a webinar to introduce a cumulative risk assessment (CRA) framework that takes into account multiple exposures to chemical and non-chemical stressors. Sarah Vogel, Senior Vice President for Health at EDF, moderated the webinar. According to Vogel, for decades, environmental justice leaders have documented disproportionate chemical exposures to disadvantaged communities. These chemical and social stressors (e.g., racism and lack of access to healthcare) contribute to adverse health outcomes. Vogel stated that the U.S. Environmental Protection Agency (EPA) ignores this reality, however, evaluating each chemical under the Toxic Substances Control Act (TSCA) in isolation. EDF is concerned that continuing this practice will perpetuate the injustices to these communities and other susceptible populations. As amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg Act) in 2016, TSCA requires a holistic consideration of chemical risk and consideration of those at higher risk. To address this, EDF developed a CRA framework that provides a practical pathway for developing assessments under the framework of TSCA. The framework describes how EPA can scale up to yield fully inclusive and just assessments of chemical risk. EDF has posted a recording of the webinar. For a summary of the webinar and Bergeson & Campbell, P.C.’s commentary, please read the full memorandum.
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