Document MM67XMOnoxZ060KZxmEqJXmkk

RESPONSIBLE SCIENCE POLICY COALITION Polyfluoroalkyl Substances: Best Practices for Science Policy Decisions July 24, 2018 James Votaw, Partner Keller and Heckman LLP Jonathan Gledhill, President Policy Navigation Group RESPONSIBLE SCIENCE POLICY COALITION 1001 G STREET, NW SUITE 500 WEST, WASHINGTON , DC 20001 RSPC New PFAS Coalition Key members: 3M, Johnson Controls More members joining Objectives Provide scientific resources to public policy decisions at federal and state level Coordinate investments in research with other stakeholders to maximize value and to accelerate results RESPONSIBLE SCIENCE POLICY COALITION 1001 G STREET, NW SUITE 500 WEST, WASHINGTON , DC 20001 What We Don't Want to Do: Perchlorate 1992 First health value 4 ppb 1995 Range expanded to 4-18 ppb 2001 Draft EPA health assessment at 1 ppb 2005 NAS rejects EPA's approach 2005 EPA sets value 24.5 ppb based on NAS 2010 EPA considers values below 4 ppb 2013 EPA's science advisors reject approach 2016/2017 New EPA modeling values: >80 ppb 2019 Court-ordered deadline to set standard RESPONSIBLE SCIENCE POLICY COALITION 1001 G STREET, NW SUITE 500 WEST, WASHINGTON , DC 20001 How Can We Do Better? Accelerate, but follow, best scientific and public policy processes Concern that we are accelerating action, but not following best practices Lead to unnecessary delays and wasted resources RSPC's goal is to accelerate research and promote best practices and best available science in policy decisions RESPONSIBLE SCIENCE POLICY COALITION 1001 G STREET, NW SUITE 500 WEST, WASHINGTON , DC 20001 What are the Processes Underway? Analytic Chemistry Safety of Substitutes Remediation Approaches Health Effects Science Best Practices in Applying Science to Set Safe Levels RESPONSIBLE SCIENCE POLICY COALITION 1001 G STREET, NW SUITE 500 WEST, WASHINGTON , DC 20001 Health Effects Science 1,000s of PFCs Some have a lot of health studies, some have some, most have very few Virtually all studies are association studies Used to develop scientific hypotheses Lots of problems with confounders, study design, and other limitations Studies don't show the strength of association needed to support causation What do we do? Invest in next round of scientific studies Different approaches Some states moving forward, other jurisdictions waiting for more definitive evidence Ask for scientific guidance RESPONSIBLE SCIENCE POLICY COALITION 1001 G STREET, NW SUITE 500 WEST, WASHINGTON , DC 20001 Best Practices to Set Safe Levels NAS first critique of EPA health assessment in 2005 Between 2005-2009 NAS found major problems in five other assessments NAS wrote its own recommendation to EPA to reform its process in 2011 Congress directed NAS to give EPA detailed recommendations. Published in 2014 Gold standard on how to conduct a health assessment Draws upon best practices in the medical, therapy, and program evaluation. Unfortunately so far EPA, states, ATSDR not following the NAS process Concern is that skipping steps will ultimately delay public health protections RESPONSIBLE SCIENCE POLICY COALITION 1001 G STREET, NW SUITE 500 WEST, WASHINGTON , DC 20001 RSPC We want to help policy officials so that they can make enduring decisions based on the best available science Disseminate existing knowledge Accelerate research Communicate and Share lessons learned and best practices Eager to help your state with your issues RESPONSIBLE SCIENCE POLICY COALITION 1001 G STREET, NW SUITE 500 WEST, WASHINGTON , DC 20001 Devon Wm. Hill, Partner David Sarvadi, Partner James Votaw, Partner Keller and Heckman LLP (202) 434-4100 Jonathan Gledhill, President Jim Rollins, Vice-President Policy Navigation Group (703) 280-0430 RESPONSIBLE SCIENCE POLICY COALITION 1001 G STREET, NW SUITE 500 WEST, WASHINGTON , DC 20001