Search

The United States Environmental Protection Agency (US EPA) is currently refining its approach for risk assessments conducted under the amended Toxic Substances Control Act (TSCA), largely based on recommendations from the National Academies of Sciences, Engineering, and Medicine (NASEM). We identified several issues with the current TSCA risk assessment approach that were not addressed by NASEM in its recommendations. Here, we demonstrate these issues with a case study of the 'Risk Evaluation for Asbestos, Part 1: Chrysotile Asbestos,' which US EPA released in December 2020. In this evaluation, US EPA found that occupational and some consumer uses of automotive brakes and clutches that contain asbestos result in unreasonable risks. These risks were calculated from estimated exposures during brake work and an inhalation unit risk (IUR) developed for chrysotile asbestos. We found that US EPA overestimated risk as a result of unrealistic inputs to both the exposure and toxicity components of the risk equation, and because the Agency did not fully consider relevant epidemiology and toxicity evidence in its systematic review. Our evaluation demonstrates areas in which the TSCA risk assessment approach could be improved to result in risk evaluations that are supported by the available scientific evidence.

We examined the development of knowledge concerning the risks posed by asbestos to seamen working aboard merchant ships at sea (i.e. commercial, rather than naval vessels). Seamen were potentially exposed to "in-place" asbestos on merchant ships by performing intermittent repair and maintenance tasks. We reviewed studies measuring airborne asbestos onboard merchant ships and health outcomes of merchant seamen, as well as studies, communications, and actions of U.S. organizations with roles in maritime health and safety. Up to the 1970s, most knowledge of the health risks of asbestos was derived from studies of workers in asbestos product manufacturing and asbestos mining and milling industries, and certain end-users of asbestos products (particularly insulators). We found that attention to the potential health risks of asbestos to merchant seamen began in the mid- to late 1970s and early 1980s. Findings of pleural abnormalities in U.S. seamen elicited some concern from governmental and industry/labor organizations, but airborne asbestos concentrations aboard merchant ships were found to be <1 f/cc for most short-term repair and maintenance tasks. Responses to this evolving information served to warn seamen and the merchant shipping industry and led to increased precautions regarding asbestos exposure. Starting in the 1990s, findings of modest increases in lung cancer and/or mesothelioma in some epidemiology studies of seamen led some authors to propose that a causal link between shipboard exposures and asbestos-related diseases existed. Limitations in these studies, however, together with mostly unremarkable measures of airborne asbestos on merchant ships, preclude definitive conclusions in this regard.