RE: Getting information to the public on CCA

[Rich Puchalsky <rpuchalsky@att.net>]

Claire Gesalman writes:
"Our draft preliminary risk assessment for penta should be completed in 2002. The results of that assessment will be available for public comment. Following the assessment of the scientific, health, and environmental data described above, EPA will determine what risk mitigation measures may be necessary to ensure that these registered products meet federal health and environmental safety standards."

Knowing the EPA public comment, decision, and rulemaking processes, I would guess that that means that no action can be taken until 2004 at the very earliest.  EPA's dioxin source assessment first pointed out the dioxin in penta in 1994 (though I suspect that, since the assessment just evaluates already-done research, the Agency knew about it long before that.)  I think that a decade is a bit much for a reaction to a potentially serious health threat in such a widely used consumer product.  Is there any way in which the process can be invested with a bit more urgency, such as by the use of EPA's powers under TSCA?

The paragraph above is addressed to the people at OPP, but the rest of the people reading this should note this as a general problem with public involvement.  The people at OPP have definitely done the best job so far of responding to public concerns that have come up "incidentally" to this discussion of public involvement.  And what do they get for it?  More criticism.  I mean, yes I think that their office has done a lousy job with pentachlorophenol and put many lives at risk.  But every branch of the EPA routinely bungles some of their responsibilities, and they don't have to hear people complain about it, because they don't listen.  In these circumstances, the temptation to lie low and meet inquiries with silence is almost irresistable, especially when institutional failure is often out of the control of EPA staff, hampered as they are by the antiquated and clumsy laws they work under and the political pressures on them and their upper management.  Some thought has to given by the people writing the draft PIP as to how to reverse this system of rewards and punishments so that those who answer inquiries are rewarded and those who don't are punished.