Earthjustice and Material Research Reveal Life Cycle Impacts of 20 Toxic Chemicals

Late one afternoon last November, attorneys for Earthjustice submitted twenty (20) technical reports to the official dockets of the U.S. Environmental Protection Agency. EPA was collecting information about these chemicals’ “conditions of use” as a part of its Toxics Substances Control Act (TSCA) review process.

According to Earthjustice, “EPA has been ignoring a wide range of chemical exposures” in its TSCA risk evaluations. Earthjustice, the premier, public interest environmental law organization, hired Material Research and our team of environmental data analysts to prepare these technical reports and identify essential “upstream and downstream” places the EPA should look in determining public health risks.

The 20 reports identify the companies responsible for making these chemicals and at what volume, the chemicals’ distributions into commerce and waste stream. We name the communities where industry pollutes the air and water with these chemicals . We overcame EPA’s tendency to cloak this kind of data under the label of “confidential business information.” Much of the data EPA accepts as proprietary is actually public in other forms; indeed, much of our research and insights came from publicly available government data.

We were able to assemble and crunch massive amounts of information in a relatively short time, thanks to Larry Kilroy, a technical strategist for Material Research who developed code that stitches together critical EPA data on toxic pollution. U.S. Customs records of chemical imports also informed our analysis.

“Material Research provided comprehensive information including from sources that are not generally available, and presented it in an accessible, user-friendly format,” said Eve Gartner, Healthy Communities Attorney for Earthjustice. “This information will prove invaluable in demanding EPA consider the full range of uses and exposure pathways in its risk calculations.”

The TSCA technical reports that are now part of the public record totaled 336 pages of text and 817 citations. Our amazing team on this project included Amy Callner, Larry Kilroy, Connie Murtagh, Verónica Odriozola, Caroline Pryor, Alex Schultz, and Jill Weber.

Sharon Lerner, the award-winning environmental justice journalist, used our research to inform her article, “The War On The War On Cancer.” This extensive report, published this week in The Intercept, reveals how EPA is “gutting regulations” for polluters, and profiles people who are suffering the health consequences. “Changes made under the Trump administration,” she writes, “promise to weaken protections for Americans’ health, many of which were intended specifically to stave off cancers…. Having the Trump administration at the helm during a once-in-a-generation reassessment of toxic pollutants is especially disastrous for the effort to protect Americans from cancer.”

Click here for a gallery summarizing essential facts about the 20 subjects of Earthjustice’s submissions.

Click on any chemical name below to find the federal docket containing each technical report and accompanying comment from Earthjustice.

20 TSCA Technical Reports Submitted by Earthjustice, November 2019:

Brominated Chemicals

Chlorinated Chemicals


Organophosphorus Flame Retardants