Two developments this week got me thinking about how our government deals – or fails to deal – with risk. First, EPA proposed to ban the manufacture (including import) of chrysotile asbestos. EPA’s authority for doing so is the Toxic Substances Control Act which provides that: 
if EPA determines through a TSCA section 6(b) risk evaluation that a chemical substance presents an unreasonable risk of injury to health or the environment,… More
Concern about the impacts of Poly- and Perflouroalkyl Substances is extensive and growing. 
Without seeking to downplay the potential risks from PFAS exposure, I do think that the way we are addressing PFAS demonstrates everything that’s wrong about how we talk about, assess, and respond to environmental risk in the United States.
Exhibit 1 for my view is Senator John Barrasso, the Republican chair of the Senate Committee on Environment and Public Works. … More
Last week, the 9th Circuit Court of Appeals remanded EPA’s approval of two nanosilver pesticides for use in textiles. The case, NRDC v. EPA, is a fascinating application of the issue of “how safe is safe” and, in particular, how much conservatism must be applied to risk estimates when there is significant uncertainty in the analysis.
EPA sets the acceptable exposure to pesticides under FIFRA by determining the risk and then addressing uncertainties. … More