Moving Away From “High Risk”

By Lou D’Amico, Ph.D. and Samantha Jones, Ph.D.


IRIS graphic identifierYesterday the Government Accountability Office (GAO) released their biennial High Risk Report, which lists government functions and operations identified as needing attention by Congress and the Executive Branch. EPA’s IRIS Program is on the list along with the Toxic Substances Control Act (TSCA) under the broader area, Transforming EPA’s Processes for Assessing and Controlling Toxic Chemicals. For the first time, GAO has provided ratings in five criteria to help programs gauge their progress in resolving the high risk designation.

GAO found that, specific to the IRIS Program, EPA has:

  • Met, a demonstrated commitment to, and top leadership support for, addressing problems;
  • Partially met, the development of a corrective action plan;
  • Partially met, instituting a program to monitor corrective measures;
  • Not met, demonstrating progress in implementing corrective measures; and
  • Not met, demonstrating the capacity to address problems.

We think this report shows improvement while acknowledging that there is more to do. The recommendations received from GAO, the National Research Council (NRC), and our Scientific Advisory Board Chemical Assessment Advisory Committee (SAB CAAC) provide important ongoing feedback and a framework through which EPA will ensure, as part of a multiyear process, that the IRIS Program produces timely, transparent, and high-quality scientific assessments.

As GAO noted, EPA’s leadership has reaffirmed the importance of the IRIS Program. In the coming weeks and months, you’ll hear more about IRIS activities that address issues raised by the GAO. An important one will be the IRIS multi-year plan, which reflects a reprioritization of the chemicals on the IRIS agenda to best meet Agency needs. Also, soon-to-be announced workshops will allow scientists in the IRIS Program to benefit from in-depth scientific discussions that directly inform ongoing work in our assessments.

The IRIS Program has taken a number of steps to strengthen, streamline, and clarify the science presented in our assessments. To increase capacity in an ever-changing environment, the IRIS Program has restructured the process for developing assessments, including the use of workgroups that bring together individuals with common expertise by scientific discipline (e.g., neurotoxicity), to evaluate a specific hazard. We’ve also recently implemented an executive review committee to ensure that scientific decisions are discussed by a greater number of senior scientists and managers within EPA’s National Center for Environmental Assessment, and to maintain quality and consistency across assessments.

Demonstrating progress is the criterion that presents a significant challenge to IRIS. The number of posted final assessments is only one measure of progress. In recent years, the same staff and managers that work on assessments have also been implementing recommendations from the GAO and NRC. One of those recommendations, adopting systematic review methodologies, is an ongoing effort. In the coming months, the public will see new sections of the IRIS Handbook, including a collection of the procedures and protocols we’ll use to implement systematic review in the IRIS Program. It is also important to advance chemicals at every stage of the IRIS process. Since 2013, IRIS has held bimonthly public science meetings on 12 chemicals under assessment. Finally, it’s important to consider the impact of these assessments. How should the IRIS Program balance the completion of complex assessments with widespread interest (which require greater resources and time) with those that may present fewer challenges and have comparatively less interest, but still have important public health impacts? The recently finalized IRIS assessment of Libby Amphibole Asbestos is only one assessment, but the impact to other federal and state agencies, and local communities is significant. Regardless of the metrics, the IRIS Program is committed to increasing productivity to meet the needs of the Agency and the public.

The independent reviews provided by the GAO and SAB CAAC, as well as the recent NRC review of the IRIS process, have validated a number of the steps taken by the IRIS Program. We will continue to evolve and we hope that stakeholders will continue to share their opinions with us – either in the comments sections of blog posts, on the IRIS general comments docket, or at some of our public meetings and workshops. We want to hear from you!

About the Authors: Lou D’Amico is the Acting Communications Director for NCEA. Samantha Jones is the Associate Director for Science in the IRIS Program.

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