An Evaluation of Stakeholder Influence on EPA’s Chemical Risk Values
Open AccessThis research aims to understand how external peer and interagency comments impact EPA’s final toxicological assessments of chemicals in the Integrated Risk Information System (IRIS). IRIS is a human health assessment database, which evaluates information on health effects that result from exposure to environmental contaminants. During EPA’s lengthy 26-month IRIS review process, external peer reviewers and agencies have the opportunity to comment on a draft toxicological report with proposed human health risk values (HHRV). This research compares the draft and final HHRVs and analyzes the stakeholder comments for 12 chemicals, each of which have external peer and interagency comments archived and available for public review in the IRIS database. To organize these comments, we determined and coded whether each comment “agreed” or “disagreed” with the EPA’s draft toxicological report. “Disagree” indicates that the external peer reviewer or agency suggested a change to the proposed calculation of an HHRV. Our results show that EPA is responsive to stakeholder comments. When a majority of external peer reviewers and agencies agree that a draft HHRV requires updates, EPA makes alterations in its final toxicological assessment to respond to these recommendations 81.8% of the time. Furthermore, when a majority of external peer reviewers and agencies agree with a draft HHRV, EPA retains that HHRV in the final toxicological report 84% of the time. To streamline this process, this research recommends that EPA distribute a general charge survey to external peer and interagency reviewers with a Likert scale at the beginning of each question. This delimited survey style would allow EPA to more easily organize and respond to comments, simplify the process to facilitate public comprehension, and preserve the opportunity for robust stakeholder commentary.
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